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	<title>Comments on: Poolbeg: New spin</title>
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	<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/</link>
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	<pubDate>Thu, 24 May 2012 03:44:18 +0000</pubDate>
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		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-71817</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Wed, 08 Sep 2010 21:03:11 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-71817</guid>
		<description>wow, losing 59 million, while still ripping off its customers. That's DAA territory</description>
		<content:encoded><![CDATA[<p>wow, losing 59 million, while still ripping off its customers. That&#8217;s DAA territory</p>
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		<title>By: Brendan Keane</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-71123</link>
		<dc:creator>Brendan Keane</dc:creator>
		<pubDate>Tue, 07 Sep 2010 10:29:28 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-71123</guid>
		<description>@ Ricahrd

Just to clarrify where the IWMA €2 billion number derives from.

as our analysis base we used the public accounts posted on the web for the combined four councils. Based on what the combined entities collect in waste charges from Households and Commercial enterprises and compare to what it costs them to run this service - in 2009 they have a deficit of approx €59 million and in 2010 they predict to have a deficit of €63 million. These numbers do not include costs / charges for street sweeping or litter managment or enfocrcemnt issues which we all undersatnd as public service items. So the defecit referred to only relates to 'commercial waste activities' or sectors where the councils compete against commercial operators. Interestingly most of this deficit relates to excessive costs for landfill mgt that should have been well catered for over the the full life of the facilities. Based on loosing this amount of money on-going for the next 25 years, plus €120 million commited to date in Poolbeg and finally adding in an estimate €10 - €20 million as the annual deficit due to being unable to meet the Put-or-pay clause you arrive at a potential €2 billion, cost to the tax payer / rate payer.

And right now I cannot see any reason why our predictions may be any more incorrect then yours!</description>
		<content:encoded><![CDATA[<p>@ Ricahrd</p>
<p>Just to clarrify where the IWMA €2 billion number derives from.</p>
<p>as our analysis base we used the public accounts posted on the web for the combined four councils. Based on what the combined entities collect in waste charges from Households and Commercial enterprises and compare to what it costs them to run this service - in 2009 they have a deficit of approx €59 million and in 2010 they predict to have a deficit of €63 million. These numbers do not include costs / charges for street sweeping or litter managment or enfocrcemnt issues which we all undersatnd as public service items. So the defecit referred to only relates to &#8216;commercial waste activities&#8217; or sectors where the councils compete against commercial operators. Interestingly most of this deficit relates to excessive costs for landfill mgt that should have been well catered for over the the full life of the facilities. Based on loosing this amount of money on-going for the next 25 years, plus €120 million commited to date in Poolbeg and finally adding in an estimate €10 - €20 million as the annual deficit due to being unable to meet the Put-or-pay clause you arrive at a potential €2 billion, cost to the tax payer / rate payer.</p>
<p>And right now I cannot see any reason why our predictions may be any more incorrect then yours!</p>
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		<title>By: Holbrook Fields</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70655</link>
		<dc:creator>Holbrook Fields</dc:creator>
		<pubDate>Mon, 06 Sep 2010 10:20:37 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70655</guid>
		<description>interesting discussion.</description>
		<content:encoded><![CDATA[<p>interesting discussion.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70649</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Mon, 06 Sep 2010 10:06:36 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70649</guid>
		<description>@PwngA
We're working on new projections at the moment, to be released later this year.</description>
		<content:encoded><![CDATA[<p>@PwngA<br />
We&#8217;re working on new projections at the moment, to be released later this year.</p>
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		<title>By: Physicist_with_no_green_agenda</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70642</link>
		<dc:creator>Physicist_with_no_green_agenda</dc:creator>
		<pubDate>Mon, 06 Sep 2010 09:54:12 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70642</guid>
		<description>@Richard
Thank you for your frank response. The limitations of any model can only be tested with data, which is much easier in my case; I don't have to wait a number of years for results, and I try to deal with closed systems.
Do you have any plans to revisit your previous work, or are there more pressing/important concerns to be dealt with? It would be interesting to see how the current trends in waste demand alter your projections. 

@Conor If your figures are right, and you make a strong case, Richard is correct in saying you should try to publish them. Waste management is very important and critical analysis is needed to minimise policy mistakes (directed at the gov. not Richard) and ill-judged decisions.</description>
		<content:encoded><![CDATA[<p>@Richard<br />
Thank you for your frank response. The limitations of any model can only be tested with data, which is much easier in my case; I don&#8217;t have to wait a number of years for results, and I try to deal with closed systems.<br />
Do you have any plans to revisit your previous work, or are there more pressing/important concerns to be dealt with? It would be interesting to see how the current trends in waste demand alter your projections. </p>
<p>@Conor If your figures are right, and you make a strong case, Richard is correct in saying you should try to publish them. Waste management is very important and critical analysis is needed to minimise policy mistakes (directed at the gov. not Richard) and ill-judged decisions.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70629</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Mon, 06 Sep 2010 09:33:43 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70629</guid>
		<description>@Sam
You're setting up strawpersons.</description>
		<content:encoded><![CDATA[<p>@Sam<br />
You&#8217;re setting up strawpersons.</p>
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		<title>By: Sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70627</link>
		<dc:creator>Sam</dc:creator>
		<pubDate>Mon, 06 Sep 2010 09:31:02 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70627</guid>
		<description>@ Richard,
Why impose vertical intergation. As I said before, why not allow a range of business models. Many will collect and process, some collect only, some process only.
The idea that DCC should decide the solution for all facical. How profitable has their business been over the last few years?

Revised EPA waste licences apply to landfills</description>
		<content:encoded><![CDATA[<p>@ Richard,<br />
Why impose vertical intergation. As I said before, why not allow a range of business models. Many will collect and process, some collect only, some process only.<br />
The idea that DCC should decide the solution for all facical. How profitable has their business been over the last few years?</p>
<p>Revised EPA waste licences apply to landfills</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70624</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Mon, 06 Sep 2010 09:25:36 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70624</guid>
		<description>@PwngA
In this particular case, the waste forecast is conditional on the economic forecast. We got the latter wrong.</description>
		<content:encoded><![CDATA[<p>@PwngA<br />
In this particular case, the waste forecast is conditional on the economic forecast. We got the latter wrong.</p>
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		<title>By: Physicist_with_no_green_agenda</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70598</link>
		<dc:creator>Physicist_with_no_green_agenda</dc:creator>
		<pubDate>Mon, 06 Sep 2010 08:16:20 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70598</guid>
		<description>@Richard 
"Superficial comparisons of forecast and observations reveal nothing about a model."

True, but a model that does not predict trends correctly should tell the researcher there is something wrong with their model or assumptions. Particularly if the model gives time derivatives of the wrong sign; it should set off alarm bells. Empirical observations will always trump models and approximations.

On a different note, it is great to see you highlighting inconsistencies and down right idiocies in some of the green's policies.</description>
		<content:encoded><![CDATA[<p>@Richard<br />
&#8220;Superficial comparisons of forecast and observations reveal nothing about a model.&#8221;</p>
<p>True, but a model that does not predict trends correctly should tell the researcher there is something wrong with their model or assumptions. Particularly if the model gives time derivatives of the wrong sign; it should set off alarm bells. Empirical observations will always trump models and approximations.</p>
<p>On a different note, it is great to see you highlighting inconsistencies and down right idiocies in some of the green&#8217;s policies.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70576</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Mon, 06 Sep 2010 07:14:53 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70576</guid>
		<description>@Sam
I answered Tim's question above

I addressed your issue with directing waste and BMW in previous threads: There are economies of vertical integration. The Landfill directive applies to landfills.</description>
		<content:encoded><![CDATA[<p>@Sam<br />
I answered Tim&#8217;s question above</p>
<p>I addressed your issue with directing waste and BMW in previous threads: There are economies of vertical integration. The Landfill directive applies to landfills.</p>
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		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70469</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Sun, 05 Sep 2010 23:18:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70469</guid>
		<description>@ Richard,
You haven't addressed Tim's question with regard the 'Put or Pay' clause.

You said on a related thread that you supported (the law doesn't) the ability of the LA's to direct waste collected by private waste companies to a particular facility under certain circumstances. What circumstances/conditions would these be?  Can you please make some attempt to engage in meaningful debate other than dismissing the topic?

We had this discussion with regard projected waste growth back in March (31st) where I referenced and quoted the SLR report. This was your response
''@Sam
SLR is just wrong about the assumptions in ISus and how it is used''

And that was that,

I then made my usuall arguments about why the BWM targets are not as problematic as many think to which you replied 
''@Sam
There are policy aspirations, as always, but the only policy in place, at present, to make a serious dent in BMW-to-landfill is the incinerators''

Then again you did post this on the 1st of April</description>
		<content:encoded><![CDATA[<p>@ Richard,<br />
You haven&#8217;t addressed Tim&#8217;s question with regard the &#8216;Put or Pay&#8217; clause.</p>
<p>You said on a related thread that you supported (the law doesn&#8217;t) the ability of the LA&#8217;s to direct waste collected by private waste companies to a particular facility under certain circumstances. What circumstances/conditions would these be?  Can you please make some attempt to engage in meaningful debate other than dismissing the topic?</p>
<p>We had this discussion with regard projected waste growth back in March (31st) where I referenced and quoted the SLR report. This was your response<br />
&#8221;@Sam<br />
SLR is just wrong about the assumptions in ISus and how it is used&#8221;</p>
<p>And that was that,</p>
<p>I then made my usuall arguments about why the BWM targets are not as problematic as many think to which you replied<br />
&#8221;@Sam<br />
There are policy aspirations, as always, but the only policy in place, at present, to make a serious dent in BMW-to-landfill is the incinerators&#8221;</p>
<p>Then again you did post this on the 1st of April</p>
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		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70461</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Sun, 05 Sep 2010 22:49:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70461</guid>
		<description>@ Conor, great analysis.

I can't see this link between GDP and waste growth that the ERSI see. How, for example, will the increase in the value of pharma/chem and food exports from Irleand (that may cause GDP growth) result in people producing more waste. Populatoin growth and disposable income are more relevant to waste growth, and if the ERSI think these will grow by 3-4% per annum between 2012-2025 they are seriously deluded.

Anyway, it's a mute point, because I wouldn't trust the ERSI's GDP forecaste anyway. I have no formal training in economics, and I could see the bubble was going to burst back in 2007.

As for the BMW landfill targets I have already explained on a related thread that the EPA are capping the BMW going to landfills by ammending there licences.

With regard biological treatment capacity Conor, you're forgeting to mention numerous other plants that are in the process of animal by-products validation or are just completing construction/expansion such as OD recycling, Barna, Enrich, Waddocks, McGills, Miltown. This capacity will be on stream in next few months. These coupled with the ones you mentioned mean their could even be excess capacity, and as you say if not additional capacity can be brought on stream very quickly.
Right now there is plenty of capacity which is evidenced by the fact that average gate fees have fallen from about €80 per tonne to €65 per tonne or so in the last 18 months.</description>
		<content:encoded><![CDATA[<p>@ Conor, great analysis.</p>
<p>I can&#8217;t see this link between GDP and waste growth that the ERSI see. How, for example, will the increase in the value of pharma/chem and food exports from Irleand (that may cause GDP growth) result in people producing more waste. Populatoin growth and disposable income are more relevant to waste growth, and if the ERSI think these will grow by 3-4% per annum between 2012-2025 they are seriously deluded.</p>
<p>Anyway, it&#8217;s a mute point, because I wouldn&#8217;t trust the ERSI&#8217;s GDP forecaste anyway. I have no formal training in economics, and I could see the bubble was going to burst back in 2007.</p>
<p>As for the BMW landfill targets I have already explained on a related thread that the EPA are capping the BMW going to landfills by ammending there licences.</p>
<p>With regard biological treatment capacity Conor, you&#8217;re forgeting to mention numerous other plants that are in the process of animal by-products validation or are just completing construction/expansion such as OD recycling, Barna, Enrich, Waddocks, McGills, Miltown. This capacity will be on stream in next few months. These coupled with the ones you mentioned mean their could even be excess capacity, and as you say if not additional capacity can be brought on stream very quickly.<br />
Right now there is plenty of capacity which is evidenced by the fact that average gate fees have fallen from about €80 per tonne to €65 per tonne or so in the last 18 months.</p>
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		<title>By: Conor Walsh</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70402</link>
		<dc:creator>Conor Walsh</dc:creator>
		<pubDate>Sun, 05 Sep 2010 19:32:20 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70402</guid>
		<description>@Richard

I should have chosen my words more carefully.  Your model has complicated workings and my comments related to the conclusions rather than the workings.  You have projected GDP growth of 3% to 4% per annum from 2012 onwards and your forecast for household waste growth is between 3% and 4% per annum from 2012 to 2025.

Household waste generated in Ireland in 2003 was 1,704,844 tonnes.  In 2008, the figure was 1,677,338 tonnes.  It'll be lower again in 2009 and 2010.  If you look at the trend from 2002 you should flatten out 2006 as this was an anomolous year.  The trend was as follows:

2002-2003 +1.5%
2003-2004 +1.4%
2004-2005 +1.1%
2005-2007 +0.8% (over 2 years)
2007-2008 -5.1%

If you consider that these growth rates were experienced during a period of boom and associated major immigration and the National Waste Prevention Programme was only getting started, how can you expect growth rates of 3% to 4% in the future?</description>
		<content:encoded><![CDATA[<p>@Richard</p>
<p>I should have chosen my words more carefully.  Your model has complicated workings and my comments related to the conclusions rather than the workings.  You have projected GDP growth of 3% to 4% per annum from 2012 onwards and your forecast for household waste growth is between 3% and 4% per annum from 2012 to 2025.</p>
<p>Household waste generated in Ireland in 2003 was 1,704,844 tonnes.  In 2008, the figure was 1,677,338 tonnes.  It&#8217;ll be lower again in 2009 and 2010.  If you look at the trend from 2002 you should flatten out 2006 as this was an anomolous year.  The trend was as follows:</p>
<p>2002-2003 +1.5%<br />
2003-2004 +1.4%<br />
2004-2005 +1.1%<br />
2005-2007 +0.8% (over 2 years)<br />
2007-2008 -5.1%</p>
<p>If you consider that these growth rates were experienced during a period of boom and associated major immigration and the National Waste Prevention Programme was only getting started, how can you expect growth rates of 3% to 4% in the future?</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70377</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Sun, 05 Sep 2010 18:11:35 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70377</guid>
		<description>@Conor
"Your model has ignored the National Waste Prevention Programme and has assumed that household waste will grow in line with GDP." Both statements are false.

"The EU average growth in household waste over the past c.10 years has been 0.4% per annum." So? Our model is calibrated to data from Ireland.</description>
		<content:encoded><![CDATA[<p>@Conor<br />
&#8220;Your model has ignored the National Waste Prevention Programme and has assumed that household waste will grow in line with GDP.&#8221; Both statements are false.</p>
<p>&#8220;The EU average growth in household waste over the past c.10 years has been 0.4% per annum.&#8221; So? Our model is calibrated to data from Ireland.</p>
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		<title>By: Conor Walsh</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70366</link>
		<dc:creator>Conor Walsh</dc:creator>
		<pubDate>Sun, 05 Sep 2010 17:02:35 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70366</guid>
		<description>@Richard

Your model has ignored the National Waste Prevention Programme and has assumed that household waste will grow in line with GDP.  I suggest that one is an oversight and the other is contrary  to overwhelming evidence from Ireland and Europe.  

The National Strategy on Biodegradable Waste 2006 assumed that the NWPP will impact on waste arisings by between 3% and 6%.  

The EU average growth in household waste over the past c.10 years has been 0.4% per annum.  Your projection is 9 to 10 times higher.  This is not a superficial observation.</description>
		<content:encoded><![CDATA[<p>@Richard</p>
<p>Your model has ignored the National Waste Prevention Programme and has assumed that household waste will grow in line with GDP.  I suggest that one is an oversight and the other is contrary  to overwhelming evidence from Ireland and Europe.  </p>
<p>The National Strategy on Biodegradable Waste 2006 assumed that the NWPP will impact on waste arisings by between 3% and 6%.  </p>
<p>The EU average growth in household waste over the past c.10 years has been 0.4% per annum.  Your projection is 9 to 10 times higher.  This is not a superficial observation.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70352</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Sun, 05 Sep 2010 15:41:05 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70352</guid>
		<description>@Conor
Superficial comparisons of forecast and observations reveal nothing about a model.</description>
		<content:encoded><![CDATA[<p>@Conor<br />
Superficial comparisons of forecast and observations reveal nothing about a model.</p>
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		<title>By: Conor Walsh</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70348</link>
		<dc:creator>Conor Walsh</dc:creator>
		<pubDate>Sun, 05 Sep 2010 15:05:14 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70348</guid>
		<description>@Richard

If I recall correctly, Gorecki's Addendum stated quite arrogantly that our analysis was 'inferior' to the ESRI's model.  Our analysis was based on evidence rather than theory and your ISus model contradicts the evidence.  

In 2008, you predicted that MSW arisings in Ireland would rise by c.3.5% that year. In 2009, you revised this downward to growth of 1.2%. the actual figure recorded later that year was -5.1%.  You were wrong by 6.3%, despite the fact that you were looking back at the previous year.  How can you be so arrogant about your future projections.  

You may have noticed that your client, DCC, decided not to use your projections in the 2009 Annual Progress Report for the Dublin Regional Waste Plan, published in January 2010.  They used growth rates for household waste  that were about half of your projected growth rates, when using your data would have better suited their case.  RPS produced that document, so you now have RPS, SLR and Eunomia all recognising that the ESRI's projections are over-blown.  It's not just me that has found fault with your analysis, it's three of the biggest waste management consultancy companies in the UK and Ireland.</description>
		<content:encoded><![CDATA[<p>@Richard</p>
<p>If I recall correctly, Gorecki&#8217;s Addendum stated quite arrogantly that our analysis was &#8216;inferior&#8217; to the ESRI&#8217;s model.  Our analysis was based on evidence rather than theory and your ISus model contradicts the evidence.  </p>
<p>In 2008, you predicted that MSW arisings in Ireland would rise by c.3.5% that year. In 2009, you revised this downward to growth of 1.2%. the actual figure recorded later that year was -5.1%.  You were wrong by 6.3%, despite the fact that you were looking back at the previous year.  How can you be so arrogant about your future projections.  </p>
<p>You may have noticed that your client, DCC, decided not to use your projections in the 2009 Annual Progress Report for the Dublin Regional Waste Plan, published in January 2010.  They used growth rates for household waste  that were about half of your projected growth rates, when using your data would have better suited their case.  RPS produced that document, so you now have RPS, SLR and Eunomia all recognising that the ESRI&#8217;s projections are over-blown.  It&#8217;s not just me that has found fault with your analysis, it&#8217;s three of the biggest waste management consultancy companies in the UK and Ireland.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70338</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Sun, 05 Sep 2010 14:26:22 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70338</guid>
		<description>@Tim
That's water under the bridge.</description>
		<content:encoded><![CDATA[<p>@Tim<br />
That&#8217;s water under the bridge.</p>
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		<title>By: Tim</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70334</link>
		<dc:creator>Tim</dc:creator>
		<pubDate>Sun, 05 Sep 2010 14:08:05 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70334</guid>
		<description>@Richard

You still haven't addressed the "Put or Pay" clause in this contract.

A commercially viable entity should not need this.

Let Covanta compete for the waste and not sign up taxpayers or DCC for any possible shortfalls that arise.

If they remove this clause then i'd go and cheerlead the project.

Regards,

Tim</description>
		<content:encoded><![CDATA[<p>@Richard</p>
<p>You still haven&#8217;t addressed the &#8220;Put or Pay&#8221; clause in this contract.</p>
<p>A commercially viable entity should not need this.</p>
<p>Let Covanta compete for the waste and not sign up taxpayers or DCC for any possible shortfalls that arise.</p>
<p>If they remove this clause then i&#8217;d go and cheerlead the project.</p>
<p>Regards,</p>
<p>Tim</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70259</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Sun, 05 Sep 2010 05:38:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70259</guid>
		<description>@Conor
You may want to study the addendum to the Gorecki report. It deals with the data and projection issues you raise.

There is a great opportunity for you here. We just had two papers published in the international literature. Showing us wrong is a sure publication.</description>
		<content:encoded><![CDATA[<p>@Conor<br />
You may want to study the addendum to the Gorecki report. It deals with the data and projection issues you raise.</p>
<p>There is a great opportunity for you here. We just had two papers published in the international literature. Showing us wrong is a sure publication.</p>
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		<title>By: Conor Walsh</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70205</link>
		<dc:creator>Conor Walsh</dc:creator>
		<pubDate>Sat, 04 Sep 2010 21:10:45 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70205</guid>
		<description>@ Richard Tol
I suggest that you are wrong on many of your points.  Your waste projection model cannot tell whether or not we'll meet the Landfill Directive targets.  I've looked at your conclusions and they assume that there will be no growth in the recycling rate from 2008, despite the fact that the local authorities and the waste industry are now rolling out the brown bin for both commercial and household customers.  This will surely divert several hundred thousand tonnes of BMW from landfill and you have ignored it completely.  

Your household waste growth projections for Ireland are between 3% and 4% per annum after 2012, when the equivalent figure was 0.65% during the Celtic Tiger boom years.  The EU average for household waste growth over the last few years was 0.4%.  I have no faith in your model and consequently no faith in your expertise in the area of wastes management.   

According to the EPA, we were 280,000 t/a short of the 2010 Landfill Directive target in 2008 and the brown bin alone is likely to bridge that gap by next year.  In addition, waste volumes have fallen by somewhere between 10 and 30% since 2007. If we miss the target this year, it won't be by much.  We should certainly meet it next year and in 2012, with the introduction of Indaver's 200,000t/a incinerator at Carranstown and the development of up to 500,000t/a capacity for Refuse Derived Fuel capacity at six existing Mechanical Treatment plants (Panda, Greenstar, Thorntons, Mr. Binman, Greyhound and Oxigen) and at least one new one (AES).

You state that the alternatives take a long time to build, but you are not close enough to the waste sector to see that the alternatives have been progressing quietly in the background.  The companies that I mentioned above will have 340,000 t/a RDF production capacity available this year. with at least a further 160,000 t/a to follow over the next 2 to 3 years.  With the collapse in construction, C&#38;D waste processing capacity requirements have reduced dramatically and this has freed up space and equipment at existing facilities for MBT operations.  Hence the rapid growth in RDF production capacity. 

The development of biological treatment capacity is also progressing well and while not as quick as RDF production, it's a lot quicker than development of new incinerators.  For example, Acorn Recycling built a 45,000 t/a composting plant in Tipperary with a construction period of 10 months.  Panda, Greenstar, Thorntons, AES, Mr. Binman and many others have planning permission for additional biological treatment capacity and I expect that these plants will be ready before the Poolbeg Incinerator is constructed.

I don't wish to sound anti-incineration.  I work for a consultancy that supports many incineration developments around the world and the technology is superior in some ways to the alternatives, but inferior in other ways.  I have also carried out consultancy work for the IWMA in relation to the Poolbeg project, but the points above are factual rather than my opinion.

In conclusion, Ireland can comply with the Landfill Directive targets without Poolbeg, but personally I believe that a properly sized Poolbeg incinerator developed on a purely merchant basis is the best option for the country.  A smaller plant (200Kt/a-300kt/a)without a 'put-or-pay' clause would compete fairly with the alternatives and offer no threat to recycling and no threat to the ratepayers in Dublin and the taxpayers of Ireland.  

If DCC plough on out of pure stubborness, they are condemning Dublin to 25 years of losses, currently running at €62m per annum and likely to rise under the Covanta contract.  I'm surprised that the ESRI are so unconcerned about this risk of €2bn losses over the 25 years of the contract.</description>
		<content:encoded><![CDATA[<p>@ Richard Tol<br />
I suggest that you are wrong on many of your points.  Your waste projection model cannot tell whether or not we&#8217;ll meet the Landfill Directive targets.  I&#8217;ve looked at your conclusions and they assume that there will be no growth in the recycling rate from 2008, despite the fact that the local authorities and the waste industry are now rolling out the brown bin for both commercial and household customers.  This will surely divert several hundred thousand tonnes of BMW from landfill and you have ignored it completely.  </p>
<p>Your household waste growth projections for Ireland are between 3% and 4% per annum after 2012, when the equivalent figure was 0.65% during the Celtic Tiger boom years.  The EU average for household waste growth over the last few years was 0.4%.  I have no faith in your model and consequently no faith in your expertise in the area of wastes management.   </p>
<p>According to the EPA, we were 280,000 t/a short of the 2010 Landfill Directive target in 2008 and the brown bin alone is likely to bridge that gap by next year.  In addition, waste volumes have fallen by somewhere between 10 and 30% since 2007. If we miss the target this year, it won&#8217;t be by much.  We should certainly meet it next year and in 2012, with the introduction of Indaver&#8217;s 200,000t/a incinerator at Carranstown and the development of up to 500,000t/a capacity for Refuse Derived Fuel capacity at six existing Mechanical Treatment plants (Panda, Greenstar, Thorntons, Mr. Binman, Greyhound and Oxigen) and at least one new one (AES).</p>
<p>You state that the alternatives take a long time to build, but you are not close enough to the waste sector to see that the alternatives have been progressing quietly in the background.  The companies that I mentioned above will have 340,000 t/a RDF production capacity available this year. with at least a further 160,000 t/a to follow over the next 2 to 3 years.  With the collapse in construction, C&amp;D waste processing capacity requirements have reduced dramatically and this has freed up space and equipment at existing facilities for MBT operations.  Hence the rapid growth in RDF production capacity. </p>
<p>The development of biological treatment capacity is also progressing well and while not as quick as RDF production, it&#8217;s a lot quicker than development of new incinerators.  For example, Acorn Recycling built a 45,000 t/a composting plant in Tipperary with a construction period of 10 months.  Panda, Greenstar, Thorntons, AES, Mr. Binman and many others have planning permission for additional biological treatment capacity and I expect that these plants will be ready before the Poolbeg Incinerator is constructed.</p>
<p>I don&#8217;t wish to sound anti-incineration.  I work for a consultancy that supports many incineration developments around the world and the technology is superior in some ways to the alternatives, but inferior in other ways.  I have also carried out consultancy work for the IWMA in relation to the Poolbeg project, but the points above are factual rather than my opinion.</p>
<p>In conclusion, Ireland can comply with the Landfill Directive targets without Poolbeg, but personally I believe that a properly sized Poolbeg incinerator developed on a purely merchant basis is the best option for the country.  A smaller plant (200Kt/a-300kt/a)without a &#8216;put-or-pay&#8217; clause would compete fairly with the alternatives and offer no threat to recycling and no threat to the ratepayers in Dublin and the taxpayers of Ireland.  </p>
<p>If DCC plough on out of pure stubborness, they are condemning Dublin to 25 years of losses, currently running at €62m per annum and likely to rise under the Covanta contract.  I&#8217;m surprised that the ESRI are so unconcerned about this risk of €2bn losses over the 25 years of the contract.</p>
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		<title>By: Dave</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70060</link>
		<dc:creator>Dave</dc:creator>
		<pubDate>Sat, 04 Sep 2010 05:18:44 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70060</guid>
		<description>The RTE report states:

"The Poolbeg incinerator contract was signed and became operative on 4 September 2007.

"It specifies that certain conditions must be met within a 36-month period.

"If these conditions have not been met, the contract stipulates, the 'parties may exercise their rights to terminate this agreement'."

Correct me if I'm wrong, but the council is the offending party here - state intervention has meant that it can't uphold its end of the contract. Why, then, would Covanta be willing to dissolve the contract on terms overwhelmingly beneficial to the council?</description>
		<content:encoded><![CDATA[<p>The RTE report states:</p>
<p>&#8220;The Poolbeg incinerator contract was signed and became operative on 4 September 2007.</p>
<p>&#8220;It specifies that certain conditions must be met within a 36-month period.</p>
<p>&#8220;If these conditions have not been met, the contract stipulates, the &#8216;parties may exercise their rights to terminate this agreement&#8217;.&#8221;</p>
<p>Correct me if I&#8217;m wrong, but the council is the offending party here - state intervention has meant that it can&#8217;t uphold its end of the contract. Why, then, would Covanta be willing to dissolve the contract on terms overwhelmingly beneficial to the council?</p>
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		<title>By: Con</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70036</link>
		<dc:creator>Con</dc:creator>
		<pubDate>Fri, 03 Sep 2010 22:43:44 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70036</guid>
		<description>The Irish Times account of DCC's statement responding to the RTE report makes two main points: 
1) That DCC has substantial sunk costs in the incinerator project.
2) That DCC would be liable for sunk costs (some? all?) at the joint venture company.
These two points seem consistent with the core assertion of the RTE report - that the contract with Covanta could be terminated or renegotiated from Sunday, without compensation to Covanta.</description>
		<content:encoded><![CDATA[<p>The Irish Times account of DCC&#8217;s statement responding to the RTE report makes two main points:<br />
1) That DCC has substantial sunk costs in the incinerator project.<br />
2) That DCC would be liable for sunk costs (some? all?) at the joint venture company.<br />
These two points seem consistent with the core assertion of the RTE report - that the contract with Covanta could be terminated or renegotiated from Sunday, without compensation to Covanta.</p>
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		<title>By: Pope Epopt</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70027</link>
		<dc:creator>Pope Epopt</dc:creator>
		<pubDate>Fri, 03 Sep 2010 21:23:43 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70027</guid>
		<description>"if well-run."  Indeed. 

I quote from that redoubtable organ, the South Wales Echo:

&lt;blockquote&gt;
In 2003 Covanta was fined $14,695 by Virginia for emitting excessive amounts of carbon monoxide from its plant at Alexandria, and for failing to submit environmental reports. In New Jersey Covanta has been repeatedly fined for releasing excessive amounts of dioxin and other toxic emissions. Massachusetts cited Covanta Energy for illegal emissions of toxic air pollutants. In October 2008 Covanta was fined $45,600 for toxic nickel emissions from a municipal waste incinerator in Pennsylvania. And in the early 1990s the city of Indianapolis, Indiana agreed a “consent decree” with Ogden Martin under which the company agreed to pay $25,000 for failing the state’s particulate emissions standards.
&lt;/blockquote&gt;

The Aarhus convention is a worthy statute, but we in Ireland also have a fine (and fined) tradition of not implementing European environmental law, until dragged into court.  Ireland and Switzerland were among the last to ratify it in Europe, and I am not aware of any real-time data feeds to which, we, the public have access.  For instance water quality results have to be dug for in county council web sites and are several weeks out of date before they see the light of day.  Perhaps Mr. Tol can point me to an example of a publicly accessible real-or-near-real-time feed.</description>
		<content:encoded><![CDATA[<p>&#8220;if well-run.&#8221;  Indeed. </p>
<p>I quote from that redoubtable organ, the South Wales Echo:</p>
<blockquote><p>
In 2003 Covanta was fined $14,695 by Virginia for emitting excessive amounts of carbon monoxide from its plant at Alexandria, and for failing to submit environmental reports. In New Jersey Covanta has been repeatedly fined for releasing excessive amounts of dioxin and other toxic emissions. Massachusetts cited Covanta Energy for illegal emissions of toxic air pollutants. In October 2008 Covanta was fined $45,600 for toxic nickel emissions from a municipal waste incinerator in Pennsylvania. And in the early 1990s the city of Indianapolis, Indiana agreed a “consent decree” with Ogden Martin under which the company agreed to pay $25,000 for failing the state’s particulate emissions standards.
</p></blockquote>
<p>The Aarhus convention is a worthy statute, but we in Ireland also have a fine (and fined) tradition of not implementing European environmental law, until dragged into court.  Ireland and Switzerland were among the last to ratify it in Europe, and I am not aware of any real-time data feeds to which, we, the public have access.  For instance water quality results have to be dug for in county council web sites and are several weeks out of date before they see the light of day.  Perhaps Mr. Tol can point me to an example of a publicly accessible real-or-near-real-time feed.</p>
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		<title>By: sam</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70026</link>
		<dc:creator>sam</dc:creator>
		<pubDate>Fri, 03 Sep 2010 21:18:17 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70026</guid>
		<description>@Richard
It's funny that you say 'new spin' when it is you that not willing to change your view after this new information has come to light
Your argument was, the contract is signed, there is no point complaining, there is nothing we can do now (sorry I'm too lazy with a couple of guinness down to go back and quote you verbatum, will do later if you dispute this).
It is clear now that there may be a break clause that can be used. There has been a huge number of changes since 2007 that may enable DCC to enact the clause legitimatly, the main one being the fact DCC cannot garrantee the supply of waste because they no longer control the waste of Dublin City when they thought they did.
Of course we still can't be sure because we haven't seen the contract.</description>
		<content:encoded><![CDATA[<p>@Richard<br />
It&#8217;s funny that you say &#8216;new spin&#8217; when it is you that not willing to change your view after this new information has come to light<br />
Your argument was, the contract is signed, there is no point complaining, there is nothing we can do now (sorry I&#8217;m too lazy with a couple of guinness down to go back and quote you verbatum, will do later if you dispute this).<br />
It is clear now that there may be a break clause that can be used. There has been a huge number of changes since 2007 that may enable DCC to enact the clause legitimatly, the main one being the fact DCC cannot garrantee the supply of waste because they no longer control the waste of Dublin City when they thought they did.<br />
Of course we still can&#8217;t be sure because we haven&#8217;t seen the contract.</p>
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		<title>By: Al</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-70010</link>
		<dc:creator>Al</dc:creator>
		<pubDate>Fri, 03 Sep 2010 20:05:43 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-70010</guid>
		<description>@ Ryano
Could he have ment Tol's?</description>
		<content:encoded><![CDATA[<p>@ Ryano<br />
Could he have ment Tol&#8217;s?</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-69991</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Fri, 03 Sep 2010 18:08:09 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-69991</guid>
		<description>@J&#38;V
You're no trolls. You stay on topic and you argue on merit.</description>
		<content:encoded><![CDATA[<p>@J&amp;V<br />
You&#8217;re no trolls. You stay on topic and you argue on merit.</p>
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		<title>By: Richard Tol</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-69990</link>
		<dc:creator>Richard Tol</dc:creator>
		<pubDate>Fri, 03 Sep 2010 18:05:38 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-69990</guid>
		<description>@Pope Epopt
Incinerators are innocent if well-run. Close monitoring is key. Such data are in the public domain per Aarhus.</description>
		<content:encoded><![CDATA[<p>@Pope Epopt<br />
Incinerators are innocent if well-run. Close monitoring is key. Such data are in the public domain per Aarhus.</p>
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		<title>By: Pope Epopt</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-69959</link>
		<dc:creator>Pope Epopt</dc:creator>
		<pubDate>Fri, 03 Sep 2010 15:52:12 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-69959</guid>
		<description>@Ryano

Don't hold your breath, Mr. Tol never defends his interventions.</description>
		<content:encoded><![CDATA[<p>@Ryano</p>
<p>Don&#8217;t hold your breath, Mr. Tol never defends his interventions.</p>
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		<title>By: Ryano</title>
		<link>http://www.irisheconomy.ie/index.php/2010/09/03/poolbeg-new-spin/#comment-69957</link>
		<dc:creator>Ryano</dc:creator>
		<pubDate>Fri, 03 Sep 2010 15:46:27 +0000</pubDate>
		<guid isPermaLink="false">http://www.irisheconomy.ie/?p=7674#comment-69957</guid>
		<description>&lt;i&gt;"Cue the green trolls."&lt;/i&gt;

A charming invitation to debate, even if "troll" doesn't mean what you seem to think it means.

Might I invite you in turn to take a look back at &lt;a href="http://www.irisheconomy.ie/index.php/2010/07/18/incineration-n2/" rel="nofollow"&gt;this earlier article&lt;/a&gt; and respond to the questions on how you were able to make such definitive assertions on the decision of the Competition Authority?</description>
		<content:encoded><![CDATA[<p><i>&#8220;Cue the green trolls.&#8221;</i></p>
<p>A charming invitation to debate, even if &#8220;troll&#8221; doesn&#8217;t mean what you seem to think it means.</p>
<p>Might I invite you in turn to take a look back at <a href="http://www.irisheconomy.ie/index.php/2010/07/18/incineration-n2/" rel="nofollow">this earlier article</a> and respond to the questions on how you were able to make such definitive assertions on the decision of the Competition Authority?</p>
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