Submission to waste consultation

We made a submission to the public consultations on waste policy. It refers back to our earlier work.

The proposed waste policy is roughly equal to the Eunomia report (available on the consultation site), ignoring all the critique raised. Our submission therefore just repeats points made earlier. We also emphasize the procedural lapses in policy formulation.

Here’s our conclusion:

Waste policy development in Ireland is essentially on hold. In the past three years there have been a number of consultations, but, by and large, no definitive decisions by government. The development of waste policy in Ireland appears to have imposed costs with no discernable benefits in terms of policy development. It is a
case study in how not to go about consultation. Instead of being driven by a desire to set and meet environmental goals in a cost-effective manner, the proposals are to a considerable extent based on a predetermined view that incineration, especially large incinerators, should be discouraged but with no coherent economic or environmental rationale as to why policy should have as its goal this technology-specific bias. It is not supported by the government’s own international review.

Submissions received by the DoEHLG in this area have neither been published nor responded to, even where there has been ample opportunity and time to do so. There is no sign that this paralysis will come to an end shortly. The Draft Waste Statement promises that there will be an RIA undertaken as part of “further significant consultation and engagement”. This is likely to defer any decisions until 2011 and beyond. The reputational damage to Ireland, which is likely to spread to sectors of the economy beyond waste, as well as the likely failure to reach landfill targets in 2013 and 2016, is something that should not be contemplated lightly. It is somewhat ironic that a Draft Waste Statement that talks about sustainability and moving away from landfill may well end producing a less sustainable policy and more extensive use of landfill than anticipated.

9 thoughts on “Submission to waste consultation”

  1. ‘Reputational damage’ – a tad hysterical

    The failure of the EPA to act on the license breaches didn’t even attract that ;evel of comment and it will affect the health of the locals a lot faster.

    The consultation criticisms and policy could be applied to the transport and spatial policy for the past 20 years.

  2. I trust that as this is the final day for submissions on the draft new waste policy, we will be seeing a coherent view of the future published by the Doe by Christmas (this year!). Just in time to deal with the small increase in packaging waste that may arise, which will of course be recycled. And Ireland will continue to meet its requirements under the waste landfill directive … something you published would not happen in 2010!

    lets face it Richard, ‘Reputataional Damage’ in waste mgt is the least of our problems.

  3. @Reuse
    Ireland needs FDI to generate jobs and growth. Regulation in Ireland has been discussed at the annual shareholders meeting of Covanta, and the US ambassador publicly intervened. Institutional investors across the world are aware of the issue, and would caution companies in their portfolio against exposure to the capricious behavior of Irish regulators.

  4. Ireland needs FDI in exporting industries to generate jobs and growth. Jobs and output generated by FDI in non-exporting industries will typically displace other jobs and output, typically resulting in only a modest net impact on jobs and output that may be positive or negative.

    Whatever the specific merits of the Covanta-DCC incineration project, it makes sense for Irish policy to distinguish between these two different types of FDI, as in fact it does. It’s a distinction that is likely to be easily understood by any interested party that does not have an interest in failing to understand it.

  5. We made a submission to the public consultations on waste policy. It refers back to our earlier work.

    Let’s hope that ESRI got it right this time – unlike the last one.

    Regulation in Ireland has been discussed at the annual shareholders meeting of Covanta, and the US ambassador publicly intervened.

    So, the “reputational damage” concerns Covanta shareholders? Honestly, boo-f’ing-hoo.

    A thought occurs. Are the ESRI still doing paid work for DCC and/or Covanta as regards this project?

  6. The key to the success of the new waste policy statement lies in how it addresses the competitiveness of composting and anaerobic digestion plants. A successful roll-out and take-up of the brown bin by householders and businesses will increase our MSW recycling rates to 50% and higher in a few short years and the 2013 and 2016 BMW targets will be easily achievable.

    Residual waste treatment capacity is progressing well and I envisage that our reliance on landfill will be halved in the next 5 years, even with a scaled-down Poolbeg Incinerator.

    In our submission today I have suggested a series of waste levies for 2013 that are designed to encourage waste from the bottom to the top of the waste hierarchy. These levies would put landfill costs (gate fee plus levy) at €120 to €150 per tonne, non-landfill residual treatment (including EfW and MBT) at €100 to €120 per tonne, composting /AD at €70 to €100 per tonne and recycling at €40 to €80 per tonne.

    My suggested levies for EfW and MBT are banded, based on scale, to ensure that cheap residual waste treatment does not undercut recycling, composting and AD gate fees. In this scenario, the cost-effectiveness of large facilities would benefit the Environment Fund as much as it would benefit the operator. So over-sized facilities could proceed in a manner that supports recycling and waste prevention, rather than threatening both.

    I have also suggested a subsidy of €50 per tonne on the supply or sale of MSW-sourced high grade compost and digestate. This would further encourage the roll-out and uptake of the brown bin and support high standards of product. The subsidy would be derived from the ring-fenced Environment Fund, i.e primarily from the residual waste levies. I’m sure that such a subsidy would have to be tested under State-Aid rules and I’ll leave that to the DEHLG to consider.

  7. Do you think someone could write a meaningful intellectual piece about ‘waste’ and refrain completely from using the terms levies, subsidies or their analogues. Please.

    Could I also ask someone, with the requisite knowledge, what are the amounts or proportions of the differents ‘wastes’ we generate.

    Presumable, bio-degradable waste can be landfilled. Hazardous (chemical) wastes must be processed in some manner. Metal can be collected and re-used. Wood? Glass?- I was trying to source old door-sized double glazing panels. They are dumped! How about all those gadzillions of blister-packs. How about a 5 euro levy on each piece. Think that might concentrate minds? Proscribe all non-biodegradable plastic containers and bags. No-can import!

    So what HAS to go for thermal treatment then? Hazardous bio? What else? Hazardous bio can be chemically treated to destroy ‘all known germs’. Its known as sterilization. You can read all about it in the medical texts published between 1900 and 1960. Then it can go to landfill. Straightforward but effective. Next!

    This obsession with Thermal is simply an imposed (ideological?) Reference Point. Discard it, and you will be able to start thinking about the other options. Like reduce the waste-to-be at source. Or is this too ‘boring’.

    And please don’t quote Austria to me as a model. Our societal mind-set is completely different to theirs.

    Brian P

  8. @Brian,
    Hard to know where to start with that post.

    The whole point of the changes taking place in waste mgt. is to prevent biodegradable waste going to landfill. It rots in absence of oxygen and causes release of green houses gases as well as causing servere odour nuisance and potentially environmental polution through water/groundwater contamination.
    It needs to be either segegated at source and composted, seperated after collection and biostabilised prior to landfill, or incinerated.

    Incineration and Landfill are suited to wastes that are not easily or feasibly recycled.

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