WASTE WORKING GROUP

C/O Earthwatch – Friends of the Earth Ireland, 7 Upr., Camden St., Dublin 2.

Ph: 01 - 4785140

To: Wicklow County Council

Re: Submission to the County Wicklow

Waste Management Plan, 1999.

Date : 26^th November 1999

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.

Summary

The achievement of a truly sustainable waste management system must be the primary focus of the Wicklow Waste Management Plan. We cannot sustain a throwaway society on a finite planet. We must therefore examine consumption and production patterns and consider how to close the material loop. An aggressive prevention, minimisation and reduction plan is the only way to provide a sustainable waste management system in County Wicklow. However the Wicklow plan lacks any sound initiatives to do this.

The three possible scenarios proposed in the Councils waste strategy development are focused on the lower end of the waste hierarchy. Each scenario is extremely limited and lacks initiative.

For example Scenario 1 proposes to maximise dry recycling and landfill the remainder. This is an extremely basic approach and should be expanded to include home composting, central composting, prevention and minimisation requirements for all sectors, the banning of certain streams at landfill amongst other options. The Council also state that without thermal treatment it is "difficult if not impossible" to divert more than 50% of household waste away from landfill. However the the municipality of Dilbeek, in Belgium, achieved a 60% reduction of household wastes in only six months by following implementing an effective prevention, minimisation and reduction plan.

The plan, states that scenario 3(maximise recycling, thermal treatment and landfill) "represents the most sustainable way forward in terms of achieving the waste hierarchy". Considering that all the proposed scenarios are focused on the lower end of the hierarchy, none of them could provide a sustainable solution. The favoured strategy includes incineration which is inherently unsustainable, not only because of the related environmental and health effects, but also as it requires a constant supply of waste. The Council states that 83% of its waste is combustible. There is no guarantee that waste which could be reused, recycled or composted will not be incinerated. Also incineration produces its own "waste" in the form of air pollutants and toxic ash. Incineration is an end of pipe disposal mechanism and the Council must ensure that waste is not simply shuffled from one disposal option to another.

While recycling is an important part of a plan, it must be remembered that it is part of the solution but not the solution. Recycling alone does not address the root problems of our unsustainable production and consumption patterns. Therefore recycling must not be used as a cureall solution which could mask the real problem.

It is recommended that the council address the unsustainability of the plan by conducting intensive research into the positive and successful prevention, minimisation reuse and recycling strategies implemented abroad.

Also the Council should incorporate the importance of producer responsibility into its awareness and fully execute its responsibilities under the 1997 Waste Management (Packaging) Regulations, as well as the 1996 Waste Management Act and the 1997 Waste Management (Planning) Regulations.

The Council fails to address the pollution potential of waste. It is necessary to incorporate this and requirements for prevention and minimisation into the Council’s licensing systems.

To achieve a sustainable waste management practices, the Council must direct its attention on prevention, minimisation and reuse option, together with recycling, to move away from end of pipe disposal mechanisms.

Introduction

The focus of the Wicklow County Waste Management Plan must be the achievement of a truly sustainable waste management system. Therefore, the plan is examined with this focus in mind. We cannot run a throwaway society on a finite planet. For this reason, our current production and consumption patterns are discussed. It is illustrated that, closing the material loop is crucial to achieving a sustainable waste management system.

The prevention and minimisation policies of the Council are examined as the prevention of waste is the single most important initiative towards achieving sustainable waste management.
Clean production and producer responsibility are discussed as methods to prevent waste and close the material loop.
Examples of proactive waste prevention and minimisation and reuse initiatives, from abroad, are given.
The proposed waste management strategies are discussed and analysed in light of their sustainability.
Attention is also given to the importance of addressing pending Community Acts.

Notes

In the body of this report:

• the Wicklow County Waste Management Plan is referred to as "the Plan",
• Wicklow County Council is referred to as "the Council".

1.Sustainable Waste Management

"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"

For this to be achieved, there is a need to change society’s perceptions of waste. To many waste management has wrongly become synonymous with disposal and, more favourably, recycling. A lot of emphasis is placed on recycling in this plan. This is positive as recycling increases the awareness that waste is more than a useless rubbish. However, although putting adequate infrastructure in place to maximise recycling rates is a necessary part of a plan, it must be remembered that it is part of the solution but not the solution. Recycling alone does not address the root problems of our waste problems. The solution lies in examining our current consumption and production patterns.

Industrial development and its associated waste products has accelerated at a rate far surpassing the adaptive capacity of natural systems to adapt to. If wastes continue to be produced at current or increased volumes, then any system, no matter how clever will eventually become overwhelmed. This rapid depletion of the Earth’s natural resources for use in production processes endangers 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.In fact, currently 20% of the world’s population consumes 80% of resources.

The following points go someway towards demonstrating the imbalance between current consumption and production patterns and the natural capacity of the Earth’s systems.

• 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 Earth’s 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.

This illustrates the fact that our current use of resources follows a predominately linear pattern.

i.e. Resources → product → disposal

We extract resources, buy and use a product and then throw it away. This illustrates the unsustainability of single use, disposable products. The focus has for too long been on the last step of this process. What we must achieve is the closing of the material loop.This is supported by the EU’s fifth environmental action programme where the central concept is to act at source to protect the environment, by encouraging changes in production processes and consumer choice, combining direct and indirect incentives and extending the range of policy instruments.

To act at source involves taking a preventative approach.

2. Prevention and Minimisation

According to the UN Conference on Environment and Development (1992), a preventative waste management approach focused on changes in lifestyles and production and consumption patterns offers the best chance for reversing current trends.

This is because preventing waste conserves scarce resources and reduces the amount of waste requiring disposal. It tackles the root problem of our unsustainable patterns of production and consumption.

The prevention of waste is therefore the single most important initiative towards achieving sustainable waste management. It encourages the exploration of safer alternatives and the development of clean and sustainable products and technologies.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.

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.

2.1 The Prevention and Minimisation of Industrial and Commercial Waste.

In relation to industry and commerce, research has shown that the key elements of most waste reduction success stories usually involve the following:

• convincing senior management of the importance of waste reduction
• obtaining senior management support for programs
• conducting a waste audit
• reducing waste where possible
• reusing packaging and materials where possible
• recycling materials that cannot be reduced or reused
• involving the plant staff in the program

Other key elements would of course include, measures to reduce the toxicity of waste by elimination and substitution.

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

• product designs which enable after use repair, or at least recycling and recovery;
• preference to be given to suppliers of materials and goods with a minimum amount of packaging;
• introduction of washable dishwear in canteens;
• provision of life-cycle information on products;
• use of recycled paper, double sided photocopies etc.

Section 4.6.2 states that the Council will encourage all enterprises to initiate waste audits and minimisation programmes and will provide support to businesses wishing to reduce the amount of waste that they produce. This is a positive start to the process.

However, the support and advice granted to industry must address the root problems of our excessive waste generation. The message that we cannot sustain a throwaway society on a finite planet must be delivered.

The Council must play a major role in delivering the message that the vast majority of current production practices are unsustainable.

As well as encouragement, actions that the Council should take include:

• Making waste prevention and minimisation an integral part of the industrial licensing process for activities within their functional area. These licenses should include targets for waste prevention and minimisation.
• As well as targeting the actual quantities of waste produced, it is also important that the pollution-potential of waste be reduced. This should be prioritised when granting licenses and analysing audits.

The plan lacks any initiatives to address the pollution potential of waste and this must be dealt with in the revised plan.

• establishing differential landfill charging, with significant increase of charges for mixed commercial and industrial waste.
• 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 must be remembered 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.

Clean Production is an excellent example of how to achieve this.

2.2 Clean Production

Clean production ultimately means the use of renewable energy and materials, the minimal use of resources, the design of sustainable products and the generation of waste that is benign and for the most part, returnable to the production process.Much of the current thinking on environmental protection focuses on what to do with wastes and emissions after they have been created. The goal of clean production is to avoid generating waste in the first place and to minimise the use of raw materials and energy.

Clean production fully endorses the precautionary and preventative principles. Producer responsibility is an efficient tool to achieve clean production as it facilitates the cyclical use of resources.

2.3 Producer Responsibility

It is stated in Section 4.8.1 that the Waste Management (Packaging) Regulations, 1997 place "onerous obligations" on producers. It should be noted that these regulations were brought into being in response to the EU Packing Directive, which was brought about in order to harmonise positive initiatives that were already in place in other countries.Packaging is regarded, by the EU, as a priority waste stream. Packaging is now estimated to form up to half the volume of municipal waste in Western Europe. Only 10-15% of packaging waste was recovered.

These regulations introduced the reality of producer responsibility to Ireland. Producer responsibility is a major tool in the evolvement of sustainable production patterns. The aim of producer responsibility is to encourage producers to prevent pollution and to reduce resource and energy use in each stage of the product life-cycle through changes in product design and process technology. In its widest sense it is the principle that producers bear a degree of responsibility for all the environmental impacts of their products. This includes upstream impacts arising from the choice of materials and from the manufacturing process and downstream impacts from the use and disposal of products. Producers accept their responsibility when they accept legal, physical or economic responsibility for the environmental impacts which can’t be eliminated by design. This means that producers accept responsibility for products at the end of their useful life. The model example is product take-back where a producer takes back a product at the end of its useful life ( a concept sometimes referred to as extended producer responsibility).

Beyond the physical requirement of returning products or packaging, this principle can be implemented by the producer funding the return and reuse of their product. Also producer responsibility is a way to shift waste management cost from the public sectors, back to the private sector. Today responsibility for the disposal of products rests ultimately on the on local government and the taxpayer, not the producer.

Producer responsibility is merely an extension of the polluter pays principle

It can be argued that by incorporating the cost of collection and recycling, industry will have a direct financial interest to minimise waste and local government would be relieved of the burden of running marginal recycling programs.

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"

Producer responsibility is rapidly becoming a significant aspect of EU waste policy. This is recognised by our Government in their policy document, where Section 8.1 states that "Producer responsibility obligations (PROs) intended to influence production and consumption patterns, minimise waste generation and will be an increasingly significant aspect of waste management policy".

The importance of producer responsibility as a tool to close the material loop coupled with the fact that companies can benefit financially, must be incorporated into awareness programmes aimed at industry and commerce.

There are eight companies in Co. Wicklow registered with REPAK.
The Council has the responsibility for enforcement of the 1997 Waste Management (Packaging) Regulations on non-REPAK members. This responsibility facilitates the Local Authorities discussion of methods of packaging prevention and minimisation with these companies. The Council must not consider the responsibility on producers as arduous. Rather their responsibilities must be viewed as an effective tool to close the material loop, and the Council must execute its full role in enforcing these regulations.

2.4 The Prevention and Minimisation of Domestic Waste

The Council does not effectively assess any measures to address the prevention or minimisation of domestic waste. It has commited itself to raising awareness. However coupled with this action must be taken.Ann effective is the approach to the prevention and minimisation of waste is the one used by the metropolitan area of Melbourne, Australia.They outlined domestic waste hierarchy, in its simplest form, as follows:

• Consumption reduction
• Product re-use; and
• Material recycling

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

They set an overall waste reduction goal for a 65% reduction in domestic waste over a ten year period. 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).

It is necessary that the Council effectively research the many excellent strategies that are in place in many countries. Another novel example is the approach used by the municipality of Dilbeek where they reduced their household waste by over 60% within 6 months. This example is discussed further in Section 4.

It is important that the Council recognises the importance of community involvement in implementing the plan.
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.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:

• it allows messages of waste reduction to be taken to a wide range of people in a wide range of communities
• it provides for peer education on one on one communication, which can be a highly effective means of influencing peoples attitudes and behaviours
• the program has considerable flexibility to adapt to the specific needs and circumstances of different communities.

Earth Works is a highly cost effective method of community education for waste reduction and home composting as much of the ground work is done by volunteers.

2.5 Analysis of Wicklow Council’s Waste Prevention and Minimisation Policy

It is stated in Section 2.5.4, of the Plan that as part of a county-wide waste minimisation programme, commercial and industrial waste is no longer accepted for collection and commercial waste is no longer accepted at the landfills operated by the Council. This would result in a reduction of the amount of waste presented to the Council for collection and taken to the Council’s landfills. It does not necessarily minimise the amount of waste produced.

This move by the Council is therefore not an incentive to minimise waste per se and is misleading if included in this section.This action is also deemed as progress in waste minimisation in Section 4.5.1. However progress in waste prevention must be interpreted as a decrease in waste generated and a move towards closing the material loop.Section 2.9 discusses the deficiencies in the current waste management infrastructure. A short paragraph entitled waste minimisation/ prevention and education discusses lack of awareness. This does not adequately address lack of prevention and minimisation initiatives.

The lack of such initiatives is also present in the short term policy of the Council as outlined in Section 4.5.3., where the Council merely states that it will continue not to handle commercial waste and will limit households to two refuse bags per week. It must be reiterated that this minimises the amount of waste going to the Council’s landfills, not waste generated.

Banning all commercial waste from landfill simply means that a private contractor will be employed to collect the waste. It is recommended that as a tool to promote prevention, minimisation and recovery, it would be more beneficial to ban those waste streams which are easily diverted from landfill, such as organic waste, office paper, packaging, wood etc.

The Council has not addressed waste prevention and minimisation sufficiently. A lack of awareness of the many highly successful schemes implemented in other countries is evident. It is crucial that the Council research these as they are indicators of truly sustainable solutions.The Council states in Section 1., of the Plan that the prevention and minimisation of waste is a primary aim of the plan. However it is not made clear how the Council proposes to bring this aim to reality. The lack of attention paid to prevention and minimisation in the Plan, is apparent yet again in Section 4, Waste Strategy Development. In the three possible scenarios put forward, none include prevention and minimisation. This is discussed further in Section 4.

3. Reuse

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 two 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 collected old refrigerators from households, free, as a means of reducing electricity use, and hence defer the need to augment its supply capacity. The Northeast Utility of Hartford, Connecticut anticipated there were many household who continue to use old refrigerators, often intermittently, even after they had purchased a new unit.When surveying a new unit, the Utility found that 10% of households said they would be willing to surrender old appliances if there was a simple way of doing so. This figure rose to one third when an offer of free pick-up was also made.

So the Utility established such a collection with the following results:

• removal of 13,600 refrigerators from its 1.2 million customer area in eight months;
• saving an estimated 14 million kW-h (enough to power 2300 homes);
• recover 1200 tons of scrap metal for recycling;
• controlled removal of 6000 pounds of CFCs and controlled recovery of PCBs from capactitors;
• average savings of US$100 in energy bills to households who handed in old refrigerators;
• saving 23,150 cubic yards of landfill area; and
• creation of 45 full and part-time jobs with a payroll of US$500 000.

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

Also, 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.

This last example should be useful to the Council in light of the Pending Waste from Electrical and Electronic Equipment (WEEE) Directive.

4.Analysis of the Council’s Waste Strategy Development.

Section 4.4 of the Plan describes the three possible scenarios put forward by the Council.

Although Section 1.1 of the Plan states that the prevention and minimisation of waste is a primary aim of the plan, none of the 3 scenarios developed includes them.

An aggressive prevention, minimisation and reduction plan is the only way to provide a sustainable solution to the waste issues.However the Council focuses on recycling, thermal treatment and landfill, i.e. the least favourable options in the waste hierarchy.

These three scenarios are very limited and more possibilities must be examined.

For example Scenario 1 proposes to maximise dry recycling and landfill the remainder. This is an extremely basic approach and should be expanded to include home composting, central composting, prevention and minimisation requirements for all sectors, the banning of certain streams at landfill amongst other options.The consideration of recycling alone is overly simplistic and lack initiative.

It has been pointed out that while recycling is an important part of a plan, it must be remembered that it is part of the solution but not the solution.

Recycling alone does not address the root problems of our unsustainable production and consumption patterns. Therefore recycling must not be used as a cureall solution which could mask the real problem.

Section 4.4.4, of the plan, states that scenario 3 "represents the most sustainable way forward in terms of achieving the waste hierarchy". Considering that all the proposed scenarios are focused on the lower end of the hierarchy, none of them could provide a sustainable solution.
Scenario 3 includes incineration which is inherently unsustainable and the following points illustrate this.

• 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.

  The air pollution consequences of incineration in the form of dioxins, heavy metals, dust particles and acid gases with their damage to immune system capacity/foetal development, nervous system, heart and respiratory systems respectively have been well documented.

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

  Although it is said that the thermal treatment plant will be a state of the art facility, 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 hazardous waste incinerators. No less than 69% of the inspections resulted in citations for violations.

  Also during the incineration process, supposedly harmless waste items when placed in certain mixtures at high heat can produce chemical compounds previously unknown whose behaviour will not be understood and which will not be covered by legislation.

• It has been emphasised that a sustainable waste management plan must focus on prevention, minimisation and reduction. However 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, say 25-30 years. Therefore incineration is in 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.
• The plan states that "a significant bulk reduction is achieved resulting in a lower amount of residual bottom ash for disposal / recycling (c. 25% of waste input by weight, 10% by volume). (Section 4.4.7, of the Plan) It should also be noted that the ash produced by incineration occupies 40-50% of the landfill space that compacted unburnt waste would. Therefore, whilst it is often said that the ash occupies only 10% of the volume of unburnt waste, this figure is misleading as it applies to uncompacted waste.

  Furthermore, no consideration is given to the fact 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 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.

• The huge financial costs involved in thermal treatment as shown in Section 4.4.7, of the Plan, reiterates these points.

Section 4.4.3 of the Plan, states that the reduction in landfill in favour of incineration has several environmental benefits. However the looks at global warming potential, acidification, eutrophication and photochemical ozone formation only. This is far from comprehensive. For example there is no mention of the effects of dioxins or the particulate matter which would be emitted from an incinerator.

Although landfill is also associated with significant environmental and health problems, it is not reasonabel to trade one wrong method with another.

Section 4.4.7 states that recycling alone can divert less than 50% of all waste away from landfill and therefore without thermal treatment it is "difficult if not impossible" to divert more than 50% of household waste away from landfill.
However it is not possible to say this as the Council has not explored all the other, more positive, options.
The relative ease with which Wicklow can meet its targets without the introduction of unsustainable waste management methods is illustrated by the following :

The municipality of Dilbeek in Belgium effectively implemented various measure such as:

1. Self composting of organic waste
   Currently approximately 60% of the population are composting their organic waste.
2. The reduction of packaging waste
   Shop-keepers were asked to follow a new consumer policy e.g. instead of plastic bags they should provide cardboard boxes, reusable bags.
   Schools were asked to reduce products delivered in composite packaging .The population was informed and encouraged to buy less packaged products etc.
3. segregation of waste, and
4. financial advantages taking into account the polluter pays principle.

With 2/3 of the population following the waste prevention action and elimination measures proposed, the schools following a policy of excluding composite packaging and the municipal services being actively involved,

Dilbeek reduced its quantity of household wastes by more than 60% within only six months, in 1996.

With such an impressive reduction, the municipality saved about 2 million EURO in 1996 and 1997.This was a pilot project based on a voluntary participatory action, involving all the inhabitants and institutions of the municipality.

5. Pending EU Directives

According to the 1997 Waste Management (Planning) Regulations, a plan should include assessment of pending Community acts in relation to waste management and environmental standards.Two pending Community Acts of direct relevance are the Waste from Electrical and Electronic Equipment (WEEE) and the Landfill Directive. The plan has made not provided such an assessment.

6. Conclusions

The Wicklow waste management plan has not prepared the ground for a sustainable waste management system.

The plan is firmly focused on the lower section of the EU waste hierarchy.

No measures are proposed to tackle production and consumption processes.

The effective implementation of prevention and minimisation initiatives abroad has not been examined. Research must be conducted into these areas and the sound experience of other countries integrated into this plan.Examples of highly successful prevention and minimisation schemes are given in Sections 2 and 4.

The three scenarios that the Council has considered in their strategy development are basic and lack initiative.None include any prevention, minimisation or reuse initiatives. All scenarios concentrate on the least sustainable options.

The plan emphasises maximising recycling and the introduction of thermal treatment as the preferred way forward. However incineration is inherently unsustainable and whilst recycling is an important part of a sustainable waste management plan, it must be complimented by effective prevention, minimisation, reduction and reuse initiatives.The preferred scenario also requires huge financial investment.

The plan lacks any initiatives to address the pollution potential of waste.

The Council must fully execute its functions under the Waste Management Act, 1996 and the Waste Management (Packaging) Regulations, 1997 and the Waste Management (Planning) Regulation, 1997.

The Council must incorporate the importance of producer responsibility into its awareness.

The Council has not addressed the effects of pending Community acts, such as the Landfill Directive and the Waste from Electrical and Electronic Equipment (WEEE) Directive, which are of direct relevance to the plan.

References

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ETSU, 1996, Economic evaluation of the draft incineration Directive, European Commission.

Dempsy, N, T.D., Minister for the Environment and Local Government, 1998, Waste Management, Changing our Ways, The Department of the Environment and Local Government.

Friends of the Earth,1997, The Landfill Campaign Guide

Hawkin, P. Lovins,B., Hunter-Lovins,L., 1999, Natural Capital, Earthscan Publications, London.

Institute for Applied Ecology, Waste Prevention and Minimisation, Darmstadt,July 1999.

Kelleher, M, 1992, Recycling Household Waste – The Canadian Experience, Resource Integration Systems Limited, Toronto, Ontario.

Raniello, B., 1991, "Recycling White Goods: A Win/Win Situation, in Resource Recycling, August.

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