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	<title>Comments on: Municipal Waste Management Policy (ctd)</title>
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	<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/</link>
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	<pubDate>Mon, 13 Feb 2012 03:10:16 +0000</pubDate>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-41760</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Mon, 29 Mar 2010 09:26:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-41760</guid>
		<description>@Carol
The incinerator has an EPA licence under EU and Irish legislation. Dioxins are not an issue if incineration is done at a sufficiently high temperature.

@All
I opened a new thread:
http://www.irisheconomy.ie/index.php/2010/03/29/municipal-waste-management-ctd/</description>
		<content:encoded><![CDATA[<p>@Carol<br />
The incinerator has an EPA licence under EU and Irish legislation. Dioxins are not an issue if incineration is done at a sufficiently high temperature.</p>
<p>@All<br />
I opened a new thread:<br />
<a href="http://www.irisheconomy.ie/index.php/2010/03/29/municipal-waste-management-ctd/" rel="nofollow">http://www.irisheconomy.ie/index.php/2010/03/29/municipal-waste-management-ctd/</a></p>
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		<title>By: The Irish Economy &#187; Blog Archive &#187; Municipal waste management (ctd)</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-41759</link>
		<dc:creator>The Irish Economy &#187; Blog Archive &#187; Municipal waste management (ctd)</dc:creator>
		<pubDate>Mon, 29 Mar 2010 09:21:11 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-41759</guid>
		<description>[...] today&#8217;s Examiner, PJ Rudden estimates the costs of changing government waste policy (as opposed by the ESRI) at around 2.5 billion euro and warns that environmental quality may deteriorate too. [...]</description>
		<content:encoded><![CDATA[<p>[...] today&#8217;s Examiner, PJ Rudden estimates the costs of changing government waste policy (as opposed by the ESRI) at around 2.5 billion euro and warns that environmental quality may deteriorate too. [...]</p>
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		<title>By: Carol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-41499</link>
		<dc:creator>Carol</dc:creator>
		<pubDate>Fri, 26 Mar 2010 23:23:38 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-41499</guid>
		<description>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.</description>
		<content:encoded><![CDATA[<p>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. </p>
<p>So with regards to the Environmental Issues first. Incineration is alleged to be Environmentally Acceptable and Proven. </p>
<p>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? </p>
<p>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. </p>
<p>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 &#8221;acceptable&#8221; 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.</p>
<p>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.</p>
<p>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? </p>
<p>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.</p>
<p>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.</p>
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		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39444</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Wed, 10 Mar 2010 23:21:41 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39444</guid>
		<description>@ 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.</description>
		<content:encoded><![CDATA[<p>@ Richard.<br />
Sorry if I wasn&#8217;t clear.<br />
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.<br />
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.<br />
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.<br />
In 2016 we will have to provide further treatment to approx. 75 - 80 percent of the residual waste. </p>
<p> 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.</p>
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		<title>By: Joe &#38; Valerie</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39330</link>
		<dc:creator>Joe &#38; Valerie</dc:creator>
		<pubDate>Tue, 09 Mar 2010 18:33:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39330</guid>
		<description>@Richard
&lt;i&gt;That’s water under the bridge.&lt;/i&gt;

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.
&lt;a href="http://www.epa.ie/downloads/pubs/research/waste/name,25535,en.html" rel="nofollow"&gt;http://www.epa.ie/downloads/pubs/research/waste/name,25535,en.html&lt;/a&gt;

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 &lt;i&gt;water under the bridge&lt;/i&gt;.  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 &#38; V</description>
		<content:encoded><![CDATA[<p>@Richard<br />
<i>That’s water under the bridge.</i></p>
<p>Not so.  We are only now getting to grips with all the costs which DCC have been obfuscating.</p>
<p>The costs omitted by them so far include:</p>
<p>1   Cost of Bottom Ash<br />
2   Cost of Fly Ash<br />
3   CO2 cost<br />
4   Clients Representative cost<br />
5   Land purchase<br />
6   Community Gain fund<br />
7   Efficiency loss through burning sewage sludge<br />
8   Parasitic use of electricity</p>
<p>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.<br />
<a href="http://www.epa.ie/downloads/pubs/research/waste/name,25535,en.html" rel="nofollow">http://www.epa.ie/downloads/pubs/research/waste/name,25535,en.html</a></p>
<p>Full workings available to anyone - just ask.</p>
<p>The revised gate fee is now 122 euros per tonne.</p>
<p>This is higher than the cost of MBT.</p>
<p>This is not <i>water under the bridge</i>.  Some of these corrections to the original business case have come to hand only in the last few weeks. </p>
<p>If we don&#8217;t analyse the economic cost then who will?  It certainly won&#8217;t be Covanta or DCC.</p>
<p>- - -<br />
J &amp; V</p>
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		<title>By: Maurice</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39318</link>
		<dc:creator>Maurice</dc:creator>
		<pubDate>Tue, 09 Mar 2010 17:34:47 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39318</guid>
		<description>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!</description>
		<content:encoded><![CDATA[<p>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! </p>
<p>And this will all come from the south and west of Dublin, though the gridlocked traffic in Ringsend.</p>
<p>This is still the wrong project in the wrong place!</p>
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		<title>By: Antoin O Lachtnain</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39220</link>
		<dc:creator>Antoin O Lachtnain</dc:creator>
		<pubDate>Tue, 09 Mar 2010 10:42:21 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39220</guid>
		<description>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.</description>
		<content:encoded><![CDATA[<p>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.</p>
<p>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.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39211</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Tue, 09 Mar 2010 09:36:49 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39211</guid>
		<description>@Antoin
The prime purpose of incineration is to get rid of waste, but it does generate energy.</description>
		<content:encoded><![CDATA[<p>@Antoin<br />
The prime purpose of incineration is to get rid of waste, but it does generate energy.</p>
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		<title>By: Antoin o lachtnain</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39209</link>
		<dc:creator>Antoin o lachtnain</dc:creator>
		<pubDate>Tue, 09 Mar 2010 09:31:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39209</guid>
		<description>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.</description>
		<content:encoded><![CDATA[<p>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.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39162</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Mon, 08 Mar 2010 20:51:41 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39162</guid>
		<description>@sam
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.

@antoin
BMW burns fine. Incinerators produce net energy.</description>
		<content:encoded><![CDATA[<p>@sam<br />
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.</p>
<p>@antoin<br />
BMW burns fine. Incinerators produce net energy.</p>
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		<title>By: Antoin O Lachtnain</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39156</link>
		<dc:creator>Antoin O Lachtnain</dc:creator>
		<pubDate>Mon, 08 Mar 2010 20:37:44 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39156</guid>
		<description>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?</description>
		<content:encoded><![CDATA[<p>What good will incinerating BMW waste do? It won&#8217;t make it disappear, that&#8217;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&#8217;s trying to make a fire with old soggy teabags? All these things must surely have an impact on the economics?</p>
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		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39154</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Mon, 08 Mar 2010 20:32:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39154</guid>
		<description>@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.</description>
		<content:encoded><![CDATA[<p>@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.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-39014</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Mon, 08 Mar 2010 10:05:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-39014</guid>
		<description>@sam
"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.</description>
		<content:encoded><![CDATA[<p>@sam<br />
&#8220;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.&#8221;</p>
<p>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.</p>
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		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38961</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Sun, 07 Mar 2010 22:48:45 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38961</guid>
		<description>@ 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.</description>
		<content:encoded><![CDATA[<p>@ J Daly<br />
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.<br />
We cannot make a real judgement until/if the details of the contract are released.</p>
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	</item>
	<item>
		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38955</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Sun, 07 Mar 2010 21:54:45 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38955</guid>
		<description>@Joe &#38; Valerie
That's water under the bridge.</description>
		<content:encoded><![CDATA[<p>@Joe &amp; Valerie<br />
That&#8217;s water under the bridge.</p>
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	<item>
		<title>By: Oliver Vandt</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38937</link>
		<dc:creator>Oliver Vandt</dc:creator>
		<pubDate>Sun, 07 Mar 2010 17:27:03 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38937</guid>
		<description>@Sam
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.</description>
		<content:encoded><![CDATA[<p>@Sam<br />
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&#8217;t agree with them but if they believe their own projections they surely have to act in a consistent manner. That&#8217;s all I will say on this thread.</p>
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	</item>
	<item>
		<title>By: Joe &#38; Valerie</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38915</link>
		<dc:creator>Joe &#38; Valerie</dc:creator>
		<pubDate>Sun, 07 Mar 2010 13:30:32 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38915</guid>
		<description>@Oliver
&lt;i&gt;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.&lt;/i&gt;

Unfortunately for DCC there is direct evidence that the figures were &lt;i&gt;‘massaged’&lt;/i&gt; (to use the words of McKechnie J) to produce a particular outcome.  In 1997 DCC had &lt;i&gt;'prejudged'&lt;/i&gt; the outcome in favour of incineration and MBT never had a chance.

The evidence can be found in the 1997 analysis &lt;i&gt;“Technical Studies &#38; Dublin Waste Model”&lt;/i&gt;.  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 &lt;i&gt;'prejudged'&lt;/i&gt; the outcome and produced a set of figures to suit incineration.

Incineration was not then, and is not now, the &lt;i&gt;'cheapest reliable technology'&lt;/i&gt;.

A properly costed comparison of MBT v incineration should be conducted with input from all sides.
- - - -
J &#38; V</description>
		<content:encoded><![CDATA[<p>@Oliver<br />
<i>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.</i></p>
<p>Unfortunately for DCC there is direct evidence that the figures were <i>‘massaged’</i> (to use the words of McKechnie J) to produce a particular outcome.  In 1997 DCC had <i>&#8216;prejudged&#8217;</i> the outcome in favour of incineration and MBT never had a chance.</p>
<p>The evidence can be found in the 1997 analysis <i>“Technical Studies &amp; Dublin Waste Model”</i>.  The following outputs from incineration are listed on page 56 but the costs were omitted:</p>
<p>o     Slags<br />
o     Flyash<br />
o     Fluegas<br />
o     Wastewater</p>
<p>Typical costs for these would be:</p>
<p>1.  Slags (Bottom ash)<br />
Never costed – DCC propose a daft notion that this ash is to be exported from Poolbeg for &#8216;recycling&#8217; 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.</p>
<p>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.</p>
<p>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.</p>
<p>2.  Fly ash<br />
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.</p>
<p>3.  Cost of CO2<br />
Paul Gorecki&#8217;s revised ESRI report puts the cost of CO2 from incineration at € 5.60 per tonne of waste burned.</p>
<p>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.</p>
<p>These omissions from the model are so egregious that it confirms our opinion that DCC had <i>&#8216;prejudged&#8217;</i> the outcome and produced a set of figures to suit incineration.</p>
<p>Incineration was not then, and is not now, the <i>&#8216;cheapest reliable technology&#8217;</i>.</p>
<p>A properly costed comparison of MBT v incineration should be conducted with input from all sides.<br />
- - - -<br />
J &amp; V</p>
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	<item>
		<title>By: J Daly</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38911</link>
		<dc:creator>J Daly</dc:creator>
		<pubDate>Sun, 07 Mar 2010 12:03:46 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38911</guid>
		<description>@ 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 &#38; 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"  
 
http://www.epa.ie/downloads/pubs/research/waste/name,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</description>
		<content:encoded><![CDATA[<p>@ Sam<br />
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.</p>
<p>For further detail on MBT see following EPA funded report.  Chapters 10 11 &amp; 12<br />
&#8220;Critical Analysis of the Potential of Mechanical Biological Treatment for Irish Waste Management Synthesis Report for the ERTDI-funded project: 2005-WRM-MS-35&#8243;  </p>
<p><a href="http://www.epa.ie/downloads/pubs/research/waste/name,25535,en.html" rel="nofollow">http://www.epa.ie/downloads/pubs/research/waste/name,25535,en.html</a></p>
<p>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.</p>
<p>Low landfill prices are likely to be a temporary factor.  There is  unlikely to investment in new landfill capcity at the current low rates</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38873</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Sun, 07 Mar 2010 01:33:58 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38873</guid>
		<description>@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.

.</description>
		<content:encoded><![CDATA[<p>@Richard and Oliver<br />
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.<br />
The issue there for is the economics (appropriate for this forum).</p>
<p>Forget about incineration vs other technologies. It is all about the cost of the contract. </p>
<p>How can any of us make a judgement on this issue until we know what DCC are comitting to in the contract?</p>
<p>If DCC re-tendered the disposal of this waste what would the cost be given the hugely changed market.</p>
<p>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.</p>
<p>.</p>
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	<item>
		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38866</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Sun, 07 Mar 2010 00:56:54 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38866</guid>
		<description>@Oliver
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</description>
		<content:encoded><![CDATA[<p>@Oliver<br />
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&#8217;t view on this phone). As for EPA waste projections, what they don&#8217;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</p>
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		<title>By: Oliver Vandt</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38845</link>
		<dc:creator>Oliver Vandt</dc:creator>
		<pubDate>Sat, 06 Mar 2010 22:40:33 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38845</guid>
		<description>@Brian J Goggin
They would be missed.</description>
		<content:encoded><![CDATA[<p>@Brian J Goggin<br />
They would be missed.</p>
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	<item>
		<title>By: Oliver Vandt</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38844</link>
		<dc:creator>Oliver Vandt</dc:creator>
		<pubDate>Sat, 06 Mar 2010 22:38:09 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38844</guid>
		<description>@Sam
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.</description>
		<content:encoded><![CDATA[<p>@Sam<br />
I don&#8217;t know what John Gormley&#8217;s red lines are. If he rules out any incinerator then there is:<br />
1. Costs of getting out of contract.<br />
2. EU Fines from not meeting landfill targets.<br />
3. Cost of Crash MBT Programme.<br />
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 &#8220;Don Gormleone&#8221; because of his&#8230;eh&#8230;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.<br />
Opposing incineration at all costs = certain huge financial cost.</p>
<p>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.</p>
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		<title>By: Brian J Goggin</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38837</link>
		<dc:creator>Brian J Goggin</dc:creator>
		<pubDate>Sat, 06 Mar 2010 22:04:34 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38837</guid>
		<description>@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.

bjg</description>
		<content:encoded><![CDATA[<p>@Oliver Vandt:<br />
&#8220;Hopefully it will become as accepted a local landmark as the Vienna incinerator.&#8221;</p>
<p>Or the Poolbeg chimneys, soon (I understand) to be no longer with us.</p>
<p>Mind you, pretty well anything you built at Poolbeg, west of the wall, would be an improvement to the local landscape.</p>
<p>bjg</p>
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		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38833</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Sat, 06 Mar 2010 21:38:12 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38833</guid>
		<description>@oliver
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).</description>
		<content:encoded><![CDATA[<p>@oliver<br />
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.<br />
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&#8217;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.<br />
There has been dramatic deflation in landfill prices over the last couple of years (I would say in the region of 60 percent<br />
) And this makes MBT much more competitive (I am talking about landfilling stable product in compliance with landfill directive of course).</p>
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		<title>By: Oliver Vandt</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38824</link>
		<dc:creator>Oliver Vandt</dc:creator>
		<pubDate>Sat, 06 Mar 2010 21:03:59 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38824</guid>
		<description>@Richard Tol
That's fair enough. 

@All
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.</description>
		<content:encoded><![CDATA[<p>@Richard Tol<br />
That&#8217;s fair enough. </p>
<p>@All<br />
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.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38799</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Sat, 06 Mar 2010 19:08:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38799</guid>
		<description>@Oliver
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.</description>
		<content:encoded><![CDATA[<p>@Oliver<br />
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.</p>
<p>Anyway, we&#8217;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 &#8212; and we&#8217;re under time pressure because of the limits on landfill loom.</p>
]]></content:encoded>
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	<item>
		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38795</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Sat, 06 Mar 2010 18:57:53 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38795</guid>
		<description>@jc
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.</description>
		<content:encoded><![CDATA[<p>@jc<br />
The ESRI report was not polemic. It just stated things as they are.</p>
<p>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.</p>
<p>If you read the reaction in today&#8217;s and yesterday&#8217;s papers then you&#8217;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&#8217;s just not true.</p>
<p>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.</p>
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	<item>
		<title>By: jc</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38786</link>
		<dc:creator>jc</dc:creator>
		<pubDate>Sat, 06 Mar 2010 18:02:06 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38786</guid>
		<description>@ 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.</description>
		<content:encoded><![CDATA[<p>@ Richard</p>
<p>My intention was to &#8220;go after&#8221; 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. </p>
<p>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. </p>
<p>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.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Oliver Vandt</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38771</link>
		<dc:creator>Oliver Vandt</dc:creator>
		<pubDate>Sat, 06 Mar 2010 17:03:16 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38771</guid>
		<description>@JC
That is a gracious apology and I hope that the matter can be left there.</description>
		<content:encoded><![CDATA[<p>@JC<br />
That is a gracious apology and I hope that the matter can be left there.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: David O'Donnell</title>
		<link>http://www.irisheconomy.ie/index.php/2010/03/05/municipal-waste-management-policy-ctd/#comment-38768</link>
		<dc:creator>David O'Donnell</dc:creator>
		<pubDate>Sat, 06 Mar 2010 16:50:47 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=5867#comment-38768</guid>
		<description>@Joseph Curtin aka jc

Noted. Appreciated. Over and out.</description>
		<content:encoded><![CDATA[<p>@Joseph Curtin aka jc</p>
<p>Noted. Appreciated. Over and out.</p>
]]></content:encoded>
	</item>
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