Municipal Waste Management Policy (ctd)

Olivia Kelly had a remarkable sense of precognition in yesterday’s Irish Times. The Independent, the Examiner and Irish Times report again today. See also FinFacts.

Paul Gorecki sums it up nicely: There was only one valid criticism of the report and it did not change the substance of the report or its conclusions.

Here’s the abstract:

The report sets out an economic approach to municipal waste management policy in Ireland and then applies that framework to two recent policy developments. First, the proposed Section 60 policy direction to cap incineration and other matters, and second, the international review of waste management policy. These complementary policy developments sponsored by the Department of the Environment, Heritage and Local Government are designed to provide a roadmap for a new municipal waste management policy. The report questions whether these developments provide a coherent and feasible basis on which to develop waste policy. Indeed, apart from some unexceptional lessons which are consistent with current waste management policy, implementation of these proposals and recommendations is likely to lower societal welfare and increase the chances that Ireland will miss important Landfill Directive targets with consequent EU fines. The report puts forward a number of suggestions consistent with raising societal welfare while at the same time meeting the Landfill Directive targets.

The report was previously discussed here.

Update: The IWMA still does not accept the ESRI waste projections (even though EPA and DEHLG do).

Update2: Dr Dominic Hogg of Eunomia continues to think that the ESRI is wrong.

Update3: Minister Gormley argues that the international review is flawless.

59 replies on “Municipal Waste Management Policy (ctd)”

Well done to the ESRI for owning up to the error that had been made and for revising its report accordingly. Given the integrity and professionalism consistently exhibited by the ESRI staff, I am not surprised. However, in the “land of the buck stops nowhere” it is a refreshing, if solitary, example of accountability and responsiveness.

Quite apart from the continuing headache for the Minister, it does raise two important matters.

First, it is unfortunate that the ESRI is partly funded directly by public funds and partly by revenue from the provision of consulting and research services. This study was commissioned (and paid for) by Dublin City Council. There is a public perception – that is, perhaps, not without some justification – that “independent” consultants succumb to “he who pays the piper calls the tune”. I hasten to add that I am not alleging this against the ESRI in this case, but, in my experience, many consulting firms may not be as fastidious as the ESRI with the facts, evidence and analysis. It is also the case that clients craft the terms of reference to ensure that the consultants retained are prevented from conducting a full investigation of the issues, ostensibly, being addressed. Not surprisingly, more often than not, clients get the answer they want.

It would be far better if the ESRI were “unbundled” into a public policy research institute completely funded from the public purse and a separate commercial consulting and research business. I believe this dual-funding arrangement restricts its ability to investigate fully a number of important policy areas and this would remove the shackles. It would also draw a distinction between analysis conducted independently in the public interest and work performed in response to a ToR, at least partially, crafted by external clients or external funders of research projects.

Secondly, the public slanging match between the Minister’s consultants and the ESRI is unedifying and professionally demeaning – even if it provides some entertainment for the wilfully underinformed media. It would be far better if a Dail or Oireachtas Committee were empowered to conduct open hearings on this matter, to allow the Minister and his consultant to put its case and Dublin City Council and the ESRI to put theirs, to allow rebuttal and counter rebuttal, to call on other expertise as required, to make an assessment and to present its decisison which would be binding on government. This is just another example of an overmighty executive being temporarily hindered by unwelcome analysis.

And to complicate matters there are allegations, perhaps not without some credence, that the Minister is being influenced by the BANANA (Build Absolutely Nothing Anywhere Near Anyone) Brigade in his constituency. This raises the issue of the propriety of ministers retaining their parliamentary seats while being charged to decide policy in the public interest. Many other parliamentary democracies require ministers on appointment to relinquish their seats.

This “incident” raises some important questions about the role of the ESRI, the role of parliament and the propriety of ministers retaining seats in parliament that have relevance across the entire range of public policy.

On your first point, you should wonder whether the arguments put forward in this and other ESRI reports are sound.

On your second point, the Oireachtas is holding hearings on this.

Paul’s point about the ESRI funding model is peripheral to the Poolbeg controversy, which stands to be resolved on the merits of the case. But his point is important – the funding model is ad hoc, and not a satisfactory long-term arrangement.

@Richard Tol

Normal science resumes. & not a spinner in sight (yet!) as the ‘substance’ of the report stands. The intersection of science, politics, and vested interests around here is rocky ol’ territory.


Your elegant and economic use of the English language sometimes challenges us lesser mortals. Are you suggesting that the soundness of the conclusions and recommendations advanced in some/many/all? ESRI reports is compromised by the funding model?

Hearings by an Oireachtas Committee, with a built-in Government majority, rarely, if ever, deliver a decision that contradicts a Ministerial or Government policy decision. And, even if they do, they have no power to enforce this decision. These Committees are creatures of the party whips – and ultimately under the control of the governing party whips – and are designed neither to hold government to account nor to exercise any restaint on its actions. They symbolise, most starkly, the almost total impotence of the Oireachtas.


I agree the point is peripheral in this instance, but I’m pleased you recognise its importance in a broader context. And I wish (see above) I could share your confidence that this matter will be “resolved on the merits of the case”. In addition to the impotence of the Oireachtas, the conflict the Minister confronts between the demands of some of his constituents and his duty to act in the public interest adds another twist.

We appear to be dealing with a cocktail of inconvenient truths and gombeenism here.

On Thursday, heading for three years as a minister, John Gormley commissioned a high fee lawyer to produce yet another report: “an independent report in relation to the various risks and implications of the proposed incinerator to be located on the Poolbeg peninsula.”

Meanwhile, Dublin City Council says it is implementing national waste management policy.

Sorry for being unclear.

You should judge a report on its merits. If a report is sponsored, you should perhaps be more skeptical than usual. But unsponsored reports may be biased too, while reports with hidden sponsors are the most treacherous of all.

… er……while waiting for the spinners …….

…. All science … is open to questioning – this is its nature.


Many thanks for this clarification. In my view, it appears to confirm the requirement for unsponsored, but publicly funded, wide-ranging and unconstrained public policy research provided either by the Institute – reconstituted appropriately – or by some other body. It also appears to confirm the requirement to empower Oireachtas Committees to consider such research, to hear evidence from other parties and to issue binding decisions that will guide or amend the formulation of policy. In this way, any bias that might exist will be exposed.

I expect that Colm McCarthy, in BSN mode, might not welcome additional public funding for the Institute or to resource Oireachtas Committees appropriately, but it would require only limited slimming of the currently sprawling quangocracy to free up the resources and it would be the most effective and efficient means of charting a sensible and democratically-supported course out of the current economic and financial debacle – and of preventing a future repetition.

It seems to me that minister Gormley owes the ESRI an apology, but I doubt that one is forthcoming. The Greens like to take the moral high-ground but when it suits them they seem to be just as happy as any other party use dirty tricks. It is clear that rather than the public interest minister Gormley is more concerned about his electoral chances. As for the industry, they also have a vested interest, and that certainly does not include the public interest.

The Greens are as good as other political groups at jumping on passing bandwagons.

Pro-science on climate change; anti-science on GM foods and abject cowards on the choice between nuclear power and fossil fuels, the Irish variety have
never challenged their electorate.

My mother used to say, expect nothing and you shall not be disappointed, but when you present yourself as apart from the fumblers in the greasy till and their cronyism but in power you behave as their carbon copy, then prepare for ignominy and contempt.

@Paul Hunt
Fully agreed.

@David O’Donnell
I said the following on the previous thread in response to an incinerator opponent who wanted to invest in developing new MBT technology and it remains my view:

“Incineration is proven. Our public service’s record when it tries to innovate is terrible. However, when you warn that the incinerator could turn into another Terminal 2 I could well believe that. If I were to be cynical [I’ll amend that to realistic] I would say that the country is going to choose an excessively costly solution whatever happens. It’s a matter of choosing the least excessively costly one.

The ESRI are focused on minimising cost. The government is, as is its right, taking more factors into account. If the government is honest about wanting to choose the costlier option I have no objection.”

Costs for the incinerator will have to be ruthlessly controlled if it is built. I believe it will not be built – or at least not on the scale originally envisioned. Though it should be the cheaper option this is now a political issue. If the public and the government do not want the incinerator built then, providing they are willing to accept the resulting probably higher costs (including any hit from cancelling/amending the Covanta deal) it will not be built, or built on a smaller scale. If MBT is not proven and with the possiblity of fines from the EU it would be prudent to ensure that we have AN incinerator – even if happily it is in conjunction with MBT – or else we must seek a derogation while we try to develop MBT.

I suspect that the debate will now widen to include not just this incinerator but the prospects for MBT and the future management of national waste.

Is it appropriate for a barrister who lives in Mr Gormley’s constituency to be undertaking this “independent” enquiry?

If you rule out Dublin 4 residents you will have to exclude a large segment of the senior bar and I have no idea where the ESRI consultants reside but it still doesn’t seem quite right.

It’s the integrity of those who analyse the data and compile the reports that’s important, not who is funding it. To take a simplistic example, Colm McCarthy was appointed by the Minister for Finance and paid out of the public pursue for compiling the Snip II report, whose contents surely horrified several members of the government. But anyone who tried to question his professionalism in the way he approached his task or what he delivered at the end of it didn’t get very far. In the end, opinions are all well and good, but facts are facts.

On the waste management issue, politics override facts. Incineration is unacceptable to the Greens. The DCC project is doubly unacceptable because of its location. The Cabinet Statement supporting the Minister’s actions got lost in the maelstrom leading up to the resignation of the Minister for Defence a few days later; but it’s evident that what happens to Poolbeg is critical to this government remaining intact.

John Gormley is in a political situation so awkward even I feel sorry for him, although his reaction to the ESRI’s report was inexcusable (also I continue to utterly despise his party for their part in a discredited government). Gormley lead local opposition to the incinerator (complete with sticker) and hit Michael McDowell over the head repeatedly for being in cabinet and not stopping it. He has now trapped himself in a political incinerator of his own making – and the temperature is rising all the time. However, he has access to the bottomless cheque book and the massive power that comes from being the lynchpin of the government. With this super sized carrot and mega stick I expect him to escape from being the first thing to be burnt off by the incinerator.

I think Richard hit on the most important issue last December when he wrote ”I know DCC has a dual function. It should not.

My understanding is that the contract is such that the incinerator will turn a profit whether or not it incinerates. DCC will pay an annual sum and in return can burn the first N tonnes for free. If DCC delivers less than N tonnes, it still pays the full amount.

DCC is therefore keen to get waste to the incinerator, which may help to explain the behaviour that the judge disapproved of”.

The argument should not be incineration vs other technologies but the nature of the contract between DCC and covanta and how this will/might distort the waste market. We need to know the rate per tonne that DCC is fixed to pay covanta for 25 Years to know if this is a worthwhile contract or not. I know that other operators are building significant infrastructure at the moment and disposal prices are coming down as a result (hasn’t worked through to domestic customers yet admittedly). Check out the EPA website (search for waste licence applications) to see the infrastructure coming on line. This infrastructure will be competeing against eachother in an agressive market place but cannot compete with Covanta if covanta have a huge contract with a monopoly operator who are fixed to pay over the odds with tax payers money for 25 years.
I have no problem with Indaver’s planned incinerators that will compete fair and square with the other technologies.

MBT is proven by the way. Its very low tech but labour intensive but nothing magical that need proving (has anyone sat down and proven that swallows can fly)

The question is not whether or not to sign the contract. The contract was signed.

Covanta can be bought out, of course. But then we’ll also need to find an alternative destination for the waste that they would have burned. We are already short of capacity (other than landfill). The infrastructure coming on line is not sufficient: See Figure 4.1 in

It will be a while before alternatives are financed, planned, and built. In the meantime, there will be EU fines for excess landfill.

I’m a green member. I’m kind of agnostic about incineration as a waste method but to me the contract seems to stink. it looks like local government and a very well paid county manager who is unelected made a decision that a lot of people aren’t happy about. i think that the market could be distorted by such a large incinerator. i’m no expert but most likely there is some role for incineration in ireland but the size of the commitment threatens to tie us into a waste policy for years that might not suit the country. also it is a prime location to develop as an amenity for dublin’s citizens and visitors. anyway, that’s just my two cents.

Arthurstown and Balleally are closing down this year so it will be going to alternative private waste disposal until 2012-13. By this time greenstar, panda, access, etc. will have gained a foothold in the dublin market and DCC will still be paying N or N tonnes. We need to look at the contract and see if there is any ‘outs’.

@ Richard
The EPA are currently in consultation for a protocol of determing BMW component in residua waste. As it stands they are currently proposing a figure of 47 Percent BMW waste for residual waste where a brown bin system is in place. I think this doesn’t add up because it lays down no criteria for clause whereby the extent of BB usage within an area. But as it stands, this proposed level of BMW would make it quite easy to meet the initial Landfill directive targets on BMW waste.

I do read the papers but I know next to nothing about MBT – which is why I thought there should be a wider debate and Oireachtas hearings (although the Hangargate hearing gives me little confidence). I also know little about the economics of waste management. I am happy to learn therefore:

“MBT is proven by the way. Its very low tech but labour intensive but nothing magical that need proving (has anyone sat down and proven that swallows can fly).”

as from reading this post by yourself(?) on the last thread (Feb 7, 7:07 PM) I was unsure about how reliable and proven the technology is:

“@ j daly. You are correct that there are issues to be resolved with regard the stabilisation of MBT ‘unders’ but at least two facilities are producing very stabile product. I know the EPA are currently doing a lot of work on the issue at the moment and I know that the senior people in the EPA in charge of formulating the guidance docs etc are very positive re MBT from the small quantity of plant currently producing product.”

To me unless Gormley can get Covanta to walk away he would be best off agreeing to build at least a smaller incinerator because of:
1. Costs of getting out of contract.
2. EU Fines from not meeting landfill targets.
3. Crash MBT program to meet target could also be very costly – even if it did meet target – especially as will take time to get running.

MBT sounds like E Voting – an idea whose time will come but could be a disaster in the present due to faulty equipment. Are you 100% confident in the technology and how much more cheap/expensive is it? Your enigmatic second line about swallows has me worried!


Looks like the G_P PR Dept have cracked the whip on their puerile spinners – there were all over the last relevant thread on this one …… and thus far, not a single one in sight (you’re really an anarchist Holbrook (-;) …. by the way – has that apology from that ‘senior researcher’ been received yet from her fellow alumnus? … m’learned pals at the bar (sound tora_bora types M_O!) would like to know … what with the tribunal stuff toning down etc?


Politically astute – Yes. This is ‘banana skin’ on which Gov could fall.


Thanks for that. I’ll pass on to m’learned friends ………

This is now gone ‘intensely political’ ….. take care.

@David O’Donnell
I agree. It is intensely political. Joe Curtin should apologise. Internet warfare can get heated (I’m Exhibit A) but if anyone knows him please ask him to do so as it would be to his credit. I DON’T think lawyers should get involved. I am often tempted to have the entire NAMA lobby jailed due to the damage they are causing but spinning is not illegal and public debate has been warped enough in Ireland by canon law.

@Richard Tol
My current opinion is that we need AN incinerator. I am wondering though if incineration is still cheaper/more reliable than MBT? Because of the three factors I mentioned in my earlier post this would not affect the decision to go ahead with the incinerator now. Likewise I believe in the absence of evidence to the contrary that Dublin City Council are not pyromaniacs so incineration was the cheapest reliable technology at the time the decision was made. This may be awkward if it isn’t still the cheapest proven technology so I will not press you on it, especially as the issue is now so political. As I say it wouldn’t affect whether incineration is the right choice on economic grounds given where we are.

@ All

I offer my sincere apologies if comments caused damage to the reputation or offense to anyone. That was not my intention.

That is a gracious apology and I hope that the matter can be left there.

@ Richard

My intention was to “go after” the simple errors and (what I judged to be) the uncharacteristically polemic tone that I noted on my preliminary perusal of the first version of the ESRI report. I greatly admire and respect the independent research conducted by ESRI, and was rather inelegantly drawing attention to these, and the issues highlighted in a more reasoned fashion by Colm and Paul above.

For the record, I am not a member of the green party (I was formerly) and work as a contractor for several national and international organisations, as well as with the IIEA.

I say this only because the comments above could be seen to associate me with some sort of orchestrated green party spin; an association that is damaging to my professional integrity.

The ESRI report was not polemic. It just stated things as they are.

If you read the comments and the response to the comments, then you notice that (a) the main conclusions were never criticised and (b) six out of seven criticisms were unfounded.

If you read the reaction in today’s and yesterday’s papers then you’ll find that there are no substantial objections. IWMA continues to claim that the ESRI waste projections (peer-reviewed, based on Irish data, used by EPA and DEHLG) are inferior to their own (not peer-reviewed, based on non-Irish data, used by IWMA). Eunomia continues to claim that the overwhelming majority of environmental economists would favour double regulation; that’s just not true.

If the ESRI used harsh words to describe proposed policy changes, then that is because the proposals could not be cast in a more favourable light.

That question is not easy to answer. Incineration is a single technology. MBT is a catchall term for a host of technologies. That said, MBT does not dispose of waste: It only sorts waste. MBT is only profitable if the cost of sorting is more than offset by the value of the recovered products.

Anyway, we’re not starting from scratch. We have a shovel-ready project with all licences and contracts signed versus an ill-defined alternative that is a glint in the eye of a politician only — and we’re under time pressure because of the limits on landfill loom.

@Richard Tol
That’s fair enough.

My own opinion would be that a large incinerator – if not perhaps on the original scale – is inevitable. Hopefully it will become as accepted a local landmark as the Vienna incinerator.

The issues to be resolved with regard MBT are being resolved in the next few weeks by the EPA. All that need to be done is to agree a protocol for determining the stability of MBT residues destined for landfill. It is not a technological issue.
You are right that an incinerator (smaller) might be the way to go since the contract is signed but nobody really knows because we don’t know the contract details. What they could do now is seek tender proposals from other disposal operators and compare this + buy out with the covanta deal. the risks of not having control of the enough waste would also need to be factored in.
There has been dramatic deflation in landfill prices over the last couple of years (I would say in the region of 60 percent
) And this makes MBT much more competitive (I am talking about landfilling stable product in compliance with landfill directive of course).

@Oliver Vandt:
“Hopefully it will become as accepted a local landmark as the Vienna incinerator.”

Or the Poolbeg chimneys, soon (I understand) to be no longer with us.

Mind you, pretty well anything you built at Poolbeg, west of the wall, would be an improvement to the local landscape.


I don’t know what John Gormley’s red lines are. If he rules out any incinerator then there is:
1. Costs of getting out of contract.
2. EU Fines from not meeting landfill targets.
3. Cost of Crash MBT Programme.
Therefore even if MBT is only as costly as incineration – and incineration is the proven one – an incinerator should be built. The contract is signed so almost certainly nothing the SC turns up in his investigation will affect the first. Also if I was Covanta I would now have an ever growing amount of evidence that the minister is actively taking sides – cue massive lawsuit. A national newspaper has lampooned him as “Don Gormleone” because of his…eh…tough line on this issue. I am sure that he genuinely believes that incinerating waste is as primitive as incinerating witches but nevertheless he is acting like a kind of Irish GP Putin.
Opposing incineration at all costs = certain huge financial cost.

Finally, if MBT is more costly than incineration and will be for the foreseeable future then we should build the full size incinerator. There is as I say one already in the city of Vienna. Poolbeg is I believe the first municipal waste incinerator in Ireland so there is a lot of fear but once it is built opposition should die down quite quickly.

Please stop with this MBT not proven nonsense. There is nothing to it, you mechanically and manually screen the material to remove recyclables and then stablise the residual material (same process as industrial composting) prior to landfill. This process is being carried out across europe and indeed in Ireland. DCC will be using existing and soon to be existing capacity if the indiginous private sector until the incinertor is built. We will see how this works out for them. My personal reading of the current waste market is that there is huge capacity available and coming on line that will significantly reduce the costs of disposal. I suspect that the very recent deflation in disposal costs were not anticipated by DCC and the capacity out there under estimated by the ERSI (I have to study the particular section of the report which I can’t view on this phone). As for EPA waste projections, what they don’t do well is economics and growth projections. In the later days of the celtic tiger they projected growth in waste production in line with the economy. None of the policy makers and indeed private waste operators saw the bubble bursting and seem not to have adjusted there plans accordingly

@Richard and Oliver
Forget about the environment and the landfill directive. The EPA are capping BMW waste to landfill so landfill directive will be met and both landfill and incineration will be regulated appropriately by the EPA.
The issue there for is the economics (appropriate for this forum).

Forget about incineration vs other technologies. It is all about the cost of the contract.

How can any of us make a judgement on this issue until we know what DCC are comitting to in the contract?

If DCC re-tendered the disposal of this waste what would the cost be given the hugely changed market.

I fear this is a bubble price deal just like the new airport terminal. I have no problem with terminals, so long as they are not over sized and over priced.


@ Sam
MBT as currently envisaged does not lead to recycling (except for a minor amount of metals) it leads to a stabilised biowaste for landfilling with dried plastic and paper waste going to fuel cement kilns. This is recovery not recycling.

For further detail on MBT see following EPA funded report. Chapters 10 11 & 12
“Critical Analysis of the Potential of Mechanical Biological Treatment for Irish Waste Management Synthesis Report for the ERTDI-funded project: 2005-WRM-MS-35”,25535,en.html

This report states that incineration is cheaper than MBT but requires greater capital investment and a longer comitment. The economics of MBT are greatly tied up with the gate fee at Cement Kilns. See figure 11.1 of the above report.

Low landfill prices are likely to be a temporary factor. There is unlikely to investment in new landfill capcity at the current low rates

Likewise I believe in the absence of evidence to the contrary that Dublin City Council are not pyromaniacs so incineration was the cheapest reliable technology at the time the decision was made.

Unfortunately for DCC there is direct evidence that the figures were ‘massaged’ (to use the words of McKechnie J) to produce a particular outcome. In 1997 DCC had ‘prejudged’ the outcome in favour of incineration and MBT never had a chance.

The evidence can be found in the 1997 analysis “Technical Studies & Dublin Waste Model”. The following outputs from incineration are listed on page 56 but the costs were omitted:

o Slags
o Flyash
o Fluegas
o Wastewater

Typical costs for these would be:

1. Slags (Bottom ash)
Never costed – DCC propose a daft notion that this ash is to be exported from Poolbeg for ‘recycling’ in the UK or Denmark. The huge cost of transporting the bottom ash was omitted from the model. We were not allowed discuss this aspect at the oral hearings into the incinerator.

The UK recycles about 50% of bottom ash but this will now fall because the Highways Agency in October banned the use of bottom ash aggregates in road contracts following an explosion which injured workers.

The likelihood is that the ash will be land filled at whatever gate fee applies to landfill plus a potential landfill levy. In the UK the levy is currently £ 2.50 for inert material but HM Treasury has proposed to increase this to £ 72 per tonne for active material. Bottom ash is an active material because of the heavy metal content.

2. Fly ash
The original model omitted the cost of disposal – about € 10 per tonne of waste burned based on research from the original MCCK waste strategy study. Again the cost of transport was omitted.

3. Cost of CO2
Paul Gorecki’s revised ESRI report puts the cost of CO2 from incineration at € 5.60 per tonne of waste burned.

The authors of the original model, MCCK, left out the cost of disposing of these expensive products of incineration. These omissions make nonsense of the analysis and we know from Mr P J Rudden that the model has not been revisited since 1997.

These omissions from the model are so egregious that it confirms our opinion that DCC had ‘prejudged’ the outcome and produced a set of figures to suit incineration.

Incineration was not then, and is not now, the ‘cheapest reliable technology’.

A properly costed comparison of MBT v incineration should be conducted with input from all sides.
– – – –
J & V

I am picking up facts as the debate progresses. If the technology is proven then fair enough. The next question is whether it is as cheap as incineration. Your point about the relevance of the contract is also fair. I would say though that I have heard the government make projections of huge short-term population growth recently when it suited. Huge population equals huge waste. I don’t agree with them but if they believe their own projections they surely have to act in a consistent manner. That’s all I will say on this thread.

@ J Daly
The market has changed so much since that report was compiled that Its conclusions could be very different now. It will be interesting to see the cost for the disposal of the waste in the interum period before the incinerator is built.
We cannot make a real judgement until/if the details of the contract are released.

“The EPA are currently in consultation for a protocol of determing BMW component in residua waste. As it stands they are currently proposing a figure of 47 Percent BMW waste for residual waste where a brown bin system is in place. I think this doesn’t add up because it lays down no criteria for clause whereby the extent of BB usage within an area. But as it stands, this proposed level of BMW would make it quite easy to meet the initial Landfill directive targets on BMW waste.”

The EPA has refined its waste categorisation. This does not make BMW disappear. If it is to be kept from landfill, an alternative (incineration, gasification, composting) needs to be provided.

@richard. My point was that the landfill targets in the short term are not too onerous. The EPA are capping the BMW going to landfill by reviewing all licences accordingly. Assuming they use characterise BMW to satisfaction of EU then we should meet landfill targets. Absolutely alternative pre-treatment other than just 3 bin will be required for 2013-16 targets.

What good will incinerating BMW waste do? It won’t make it disappear, that’s for sure. You will not reduce its volume by much. In order to burn it, surely you will have to add something to get it to burn, otherwise it’s trying to make a fire with old soggy teabags? All these things must surely have an impact on the economics?

You lost me here. The landfill target can indeed be met by keeping BMW out. But that leaves a huge pile of waste to be disposed of. Current and planned capacity in disposal-other-than-landfill is insufficient.

BMW burns fine. Incinerators produce net energy.

The calorific value of food waste is around 4 Kj / g. This is a quarter of that of paper. Is this really enough to dry the material and achieve a safe incinerating temperature of 700 or 800 Degrees c? It is really hard for me to believe there would be any excess energy to use for power generation and I do not think any incinerator manufacturer would ever claim such a thing.

It will not necessarily generate net energy. It depends on the mix and types of waste you put in it. A teabags-only incinerating plant would not generate energy, for instance, because you would have to add fuel to the fire. A tetra-pack-only incinerating plant definitely would produce energy. The problem I am pointing to is that no account has been taken of the degree to which high-calorific-value fuels have been removed from domestic waste.

The economics of any energy-generating project depend on the quality of the fuel. What the contract says about the calorific value of the inputs – i.e., how well the waste has to burn to avoid paying a penalty has to make a big difference to whether a proposed incinerator is economically attractive or not.

Look at nodublinincinerator.webs for more new information on this subject. Especially note that this is now a NATIONAL incinerator becuse Covanta will have a contractual obligation to source 280,000 onns of waste from OUTSIDE the Greater Dublin Region!

And this will all come from the south and west of Dublin, though the gridlocked traffic in Ringsend.

This is still the wrong project in the wrong place!

That’s water under the bridge.

Not so. We are only now getting to grips with all the costs which DCC have been obfuscating.

The costs omitted by them so far include:

1 Cost of Bottom Ash
2 Cost of Fly Ash
3 CO2 cost
4 Clients Representative cost
5 Land purchase
6 Community Gain fund
7 Efficiency loss through burning sewage sludge
8 Parasitic use of electricity

We used the EfW model found in Table 11.5 on p 260 of the EPA MBT Synthesis report to re-assess the true economic cost of the Poolbeg incinerator.,25535,en.html

Full workings available to anyone – just ask.

The revised gate fee is now 122 euros per tonne.

This is higher than the cost of MBT.

This is not water under the bridge. Some of these corrections to the original business case have come to hand only in the last few weeks.

If we don’t analyse the economic cost then who will? It certainly won’t be Covanta or DCC.

– – –
J & V

@ Richard.
Sorry if I wasn’t clear.
Up to 2013 the epa will allow, in compliance with landfill directive, approx. Residual waste going to landfill to contain approx. 50 Percent BMW (exact figure to be firmed up shortly). With a 3 bin system in place (which is government policy) the residual waste will contain less than 50 Percent so can go to landfill without further treatment.
So the landfill targets are not too problematic until 2013. We therefore have 3 Years to build alternative infrastructure to treat the residual waste further to meet 2013 Target.
The 2013 target will be in the region of 30 percent BMW (again subject to EPA review to be resolved shortly). So only approx. Only 40 percent of the residual waste at this point will require treatment.
In 2016 we will have to provide further treatment to approx. 75 – 80 percent of the residual waste.

So what? So 2016 is Y-Year and we can easily build a few large sheds with aeration channels to stabilise the residual waste in 6 years. Some commentators (not yourelf) are portraying the need for the incinerator as urgent.

The various statements about incineration and its effectiveness in dealing with the residual waste arisings from Greater Dublin are noteworthy. The issue about recycling and separation of the inerts and salvageable materials are also valid. None the less after the ENVIRONMENTAL ISSUES have been tested the final arbiter is COST and AFFORDABILITY.

So with regards to the Environmental Issues first. Incineration is alleged to be Environmentally Acceptable and Proven.

If the first part of this statement was true then why is it that every few years after an event new Legislation is enacted to rectify past inadequacies? Surely the test of Environmentally Acceptable has to be capable of meeting current Legislation and Foreseen New Legislation. So what is Foreseen and what is New Legislation?

We already know that Ireland like the rest of European Union is a signatory to the Stockholm Convention on POPS (Persistent Organic Pollutants) control. This means that any and all processing plants in Ireland must control their emissions to the air and the land. Incineration does not eliminate POPS for even after controls there are escapes. And one area where this is blatantly uncontrolled is in Dioxins and similar compounds.

The EPA in the USA has declared that Dioxins are the most dangerous and harmful substances known to humans. They can be ingested through many pathways to humans. The effects on human foetuses and infant growth is as yet not fully understood, but upon ingesting they are absorbed into the very DNA of humans whereupon the natural cycle of multiplication of the in-built DNA chains means that within a space of 2 years (from inside the womb to a 15 month-old infant) the multiplication of Dioxins can be many tens or even hundreds of millions. So whilst their is a so-called ”acceptable” dose rate for humans please be reminded that it is not the same for pregnant mothers and infants. But you ask why is Dioxin liberated from Incineration facilities more dangerous than others? The answer here is simple, it is continuous and it is airborne and distributed and concentrated down-wind of such a facility. There are no safe limits for Dioxins in the atmosphere.

Under already accepted Legislation any incineration plant has to control the emission of Particulates to the size of PM10 (the legislation was enacted within the last two years.) This is after the response bid given for the Ringsend Incineration project. The costs for attenuating this are not unsubstantial, and from comparisons elsewhere may cost in excess of €100 million.

In an address recently published Dublin Corporation reluctantly had it drawn from them that provision to manage the residues (Hearth Ash/Clinker and Flue Ash) all of which is Toxic had not been catered for. Who is paying for the €100 million secure LandFill site? Your correspondents here record that this is an ongoing cost that is only forecast to be €130-00 per tonne. If that is correct and the residues are 15% of the original 600,000 tonnes per annum that would be €7,800,000 per year. However recalling that such charges elsewhere in Europe .exceed €200-00 per tonne can we assume that this is real?

Incineration is Proven Technology? Surely someone does not understand the logic of Proven and Experimental. Incineration Plants have been built and work but the outcome of the process is hardly a proven issue. Converting a Raw Material to a series of Wasted Gases and Solids whereupon there are no further uses is not the best proven example of waste management. In fact it is the treatment of last resort after all other systems have been viewed and tested for viability. Too many people hide behind the issue of Proven and BPEO (Best Practical Environmental Option) or BATNEEC (Best Available Technology Not Exceeding Excessive Cost) knowing full well that there are other systems around that offer Better Environmental Accountability as well as being Affordable. To be both at the same time is better still! And so it is. The UK/Dutch/Americans have developed a process for converting the Biomass to make the Biofuel Ethanol at a capital cost that would (i) be less than half that for Incineration (ii) not produce any emissions because the process is a wet based one, (iii) not require upgrading after a few years (iv) not entail having to increase Gate Fees for Treatment above €35-00 per tonne and after a period of say 5 to 7 years dispose of any treatment costs whatsoever. Possible? Real? Of course it is otherwise why would they be building plants in the UK Netherlands Israel VietNam Kentucky China Guam and elsewhere.

Wake up everyone Incineration is old hat outdated and an expensive mill stone of costs that hang around you for ever. Break out of this mould and get the Government out of their conviction that it is a done deal. It is not and need not.

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