ZWAI-E&MRWMP-012a Complete Submission on draft EastMidRegWasteManPlan, 30-Jan-15

ZERO WASTE ALLIANCE IRELAND Towards Sustainable Resource Management __________________________________________________________

Túr na Gaoithe Philipstown HBX

Castleblaney Road Dundalk

County Louth

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Eastern - Midlands Draft Regional Waste Management Plan 2015 - 2021

Public Consultation !!!!

Submission to the Eastern & Midlands Regional Waste

Coordinator

30 January 2014

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Túr na Gaoithe

Philipstown HBX Castleblaney Road

Dundalk County Louth

30 January 2015

Regional Waste Coordinator, Eastern & Midlands Region Waste Management Office, Block 1, Floor 6, Civic Offices, BY EMAIL TO: Dublin 8. [email protected] Dear Sir,

Eastern - Midlands Draft Regional Waste Management Plan 2015 - 2021 Public Consultation

Submission to the Eastern & Midlands Regional Waste Coordinator On behalf of Zero Waste Alliance Ireland (ZWAI), I am attaching an electronic copy of our observations on the draft Eastern & Midlands Regional Waste Management Plan 2015 – 2021. The submission provides a brief overview of our policy and objectives on waste, supporting the well-established strategy and policy of aiming for “Zero Waste”, and supporting repairing, preparation for re-use, reusing and recycling materials and objects, in accordance with the revised European Waste Hierarchy and the “Circular Economy”. Our observations express concern that the Eastern & Midlands Regional Waste Management Plan as drafted gives too much power to Dublin City Council and the other local authorities of the Greater Dublin Area, and that the midland counties will have very little or no influence in waste-related planning matters, policies or objectives which might be more appropriate at county or local level. We are also concerned that much too high a proportion of re-usable and recyclable discarded materials is sent overseas for processing, adding the environmental cost of transportation, fuel use and emissions from vessels transporting these materials. We propose that, to reduce or eliminate this dependency, Ireland should follow the

Observations by Zero Waste Alliance Ireland on the draft Eastern & Midlands region WMP

Page 2 of 2

example of other countries and that appropriate financial and other supports should be provided in the Waste Management Plan for the establishment of small, locally based repairing, preparation for re-use and recycling workshops, of the type we have seen in the Province of Flanders, Belgium. Similar initiatives are being undertaken in Ireland, but they are facing a barrier of negligible financial support by local authorities. One of our basic principles in ZWAI is that discarded materials should be segregated at source (before they become “waste”), and that these materials (together with recyclable wastes) should be used for the benefit of the communities which have produced them, and that waste collection and utilisation facilities should be community owned and controlled (but allowing for the possibility that private companies may carry out some of this activity as a service under contract and under careful regulation and control). We would therefore wish to see this type of approach included in the Waste Management Plan, together with a firm statement that the handling of our discarded materials must not be left to “market forces”, for the purpose of private gain and profit. In general, it is our observation that the draft Waste Management Plan contains some very appropriate and welcome policies and objectives, but these are not clearly stated, and the language used is, in many places, weak and ambiguous. We hope that the above observations, together with those in the attached submission, will help to influence the Plan towards a more ecological approach to waste management – in which human societies behave more like natural systems which produce nothing which cannot be fed back into the Earth’s transformational and long term sustainable processes. Yours sincerely,

Ollan Herr Jack O’Sullivan

On behalf of Zero Waste Alliance Ireland.

ZWAI-E&MRWMP-001 Covering letter to Waste Plan Co-ordinator, 30-Jan-15.doc

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Public Consultation Submission to the Eastern & Midlands Regional Waste Coordinator

CONTENTS Page

1. Introduction and preliminary comments .. .. .. .. 1

2. Excessive Size of the Waste Management Region Covered by the Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021 .. .. .. .. .. .. .. .. .. 3

3. Zero Waste Alliance Ireland (ZWAI) policy on waste and the management of waste .. .. .. .. .. .. 5

4. Implementing the circular economy .. .. .. .. 7

5. Charging by weight for waste, an improved system of waste disposal levies, and better financial support for re-use, repair and recycling .. .. .. .. .. .. .. .. 11

Proposed virgin material tax .. .. .. .. .. .. 13

Plastic type labeling tax .. .. .. .. .. .. 14

Financial support for recycling .. .. .. .. .. 14

6. Separation at source – integrating household waste segregation with the Building Regulations .. .. .. .. .. 14

Existing resource conservation and recovery in Irish Building Regulations 15

Part N – Waste resource separation and segregation in the home .. 15

Health protection .. .. .. .. .. .. 15

Formal early planning for resource separation in the kitchen 15

Storage size .. .. .. .. .. .. .. 16

For longer storage periods .. .. .. .. .. 16

Saving on the pay-by-weight charges by composting .. 17

Domestic rotating drum composters .. .. .. .. 18

Domestic vermicomposting .. .. .. .. .. 19

7. Public Consultation .. .. .. .. .. .. .. 20

Figure 1: The “Linear Economy” and the “Circular Economy” 8

Appendix I Notice on the website of the Department of the Environment, Community and Local Government inviting Comments on the draft Regional Waste Management Plans Appendix II" Acknowledgment received from Dublin City Council on 05 February 2015 !

ZWAI-E&MRWMP-011 Contents Pages of Submission on draft EastMidRegWasteManPlan, 30-Jan-15.doc

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Túr na Gaoithe Philipstown HBX

Castleblaney Road Dundalk

County Louth

!


Public Consultation !Submission to the Eastern & Midlands Regional Waste

Coordinator 30 January 2014

!!1. INTRODUCTION AND PRELIMINARY COMMENTS !One of the key issues addressed in the Government's waste management policy document, “A Resource Opportunity – Waste Management Policy in Ireland” (July 2012), is regional waste management planning; and the policy reminds us that waste management planning has been a statutory function of local authorities since 1996. Under Section 22 of the Waste Management Act, 1996, local authorities were given the discretion to come together to discharge their waste management planning functions in groups, as a result of which 10 regional waste management plans were drawn up and implemented. !This regional approach appears to have worked reasonably well, in that the number of landfills declined significantly, and a more strategic approach was taken by the groups of local authorities. On the other hand, the waste management plans failed to bring about any significant elimination of waste, to radically reduce the quantities of waste generated, or to encourage repair, re-use and re-cycling. The result of nearly 20 years of waste management has led to a situation where almost all of Ireland’s recyclable materials are exported, with very little re-processing or recycling carried out in the country.

Submission by Zero Waste Alliance Ireland

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Nevertheless, the implementation of the regional waste management system could be said to have brought about an improvement, primarily as a result of European Union Directives and a strengthening of the Environmental Protection Agency’s role in waste prevention and management. !The existence of waste management regions, within which each region was expected to become self sufficient in waste-related infrastructure, so that transportation of waste across regional boundaries would be minimized, did not appeal to the waste management industry, members of which felt strongly that waste should be transported to wherever it could be disposed of more economically. All too often, this approach resulted in waste being trucked long distances across the country to landfill sites where the gate fees were less than at other more proximate sites. As a result of this industrial sector lobbying, the boundaries of the waste management regions became more “permeable”, especially in Leinster, where large quantities of urban and industrial wastes from the ever-expanding Dublin metropolis found their final resting place in Counties Meath, Wicklow, Kildare, Louth, Offaly, Cavan and Westmeath. Some wastes may even have travelled to counties further away; and there is every likelihood that wastes generated in other cities such as Cork and Limerick were also transported to other counties for landfilling. !The most recent policy document, “A Resource Opportunity – Waste Management Policy in Ireland”, appears to have taken this move a step further, and has proposed a reduction in the number of waste regions from 10 to 3 (section 3.4, page 28). This is described as the result of “local authorities undertaking their waste management planning responsibilities, guided by the programme of reform of local government structures”, but perhaps it could be more correctly stated as the result of a policy set unilaterally by the Department of Environment, Community and Local Government, with the active suppport of the waste management industry. An indication of the industry’s influence may be found in section 2.1, page 5, of the draft Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021, which states that “the new regional structures also better recognise the nature of the Irish waste market and the movement of waste in the State”. While accepting that rationalisation and economies of scale may be beneficial in some ways, we would suggest that the size of each of the new waste management regions is too large. As this submission addresses specifically the Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021, our observations in section 2 below deal only with this region.


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2. EXCESSIVE SIZE OF THE WASTE MANAGEMENT

REGION COVERED BY THE EASTERN - MIDLANDS DRAFT REGIONAL WASTE MANAGEMENT PLAN 2015 – 2021

!Our first observation is that the creation of such an extremely large waste management area would copper-fasten the practice of transporting Dublin’s waste as far as possible from the city. While acknowledging that it is very difficult for a city to deal with its own wastes within its own boundaries, it is our view that imposing Dublin’s waste on rural communities is not the most appropriate solution. In the absence of adequate policies to implement extended producer responsibility, to adequately encourage waste reduction, resource recovery, repair, re-use and recycling or composting of organic materials, landfilling still remains one of the options taken by the waste industry in Ireland. It is therefore our submission that this new and expanded waste management region, which would come under the control of Dublin City Council, would result in that Local Authority having far too much power in comparison with all of the other Local Authorities within the same region. Not only is Dublin City Council extremely powerful by reason of its economic strength, but to add further to its power would shift the balance even more in its favour. The Regional Waste Management Plan as drafted further copper-fastens this imbalance of power because of the over-riding importance given to the policies and objectives of the Plan. In relation to the current planning framework, the draft Regional Waste Management Plan states that:1

“The waste plan is a statutory planning document setting out policies for the development of waste treatment infrastructure and sits on the same planning tier as the city and county development plans.

These local planning frameworks are deemed (under law) to contain the objectives of the relevant waste management plan in force for that particular area.

In the event of a conflict arising between an objective in the waste plan and that of a city or county development plan, the waste plan objective takes precedence and permission may be granted”.

1 Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021; section 2.2

(Planning Framework), page 8. Eastern‐Midlands Region Waste Management Office, Dublin 8.


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The quotation above makes it quite clear that policies and objectives on waste management, drawn up by the Dublin local authorities, would over-ride any local policies or objectives in the County Development Plans of any of the other counties in the Waste Management Region. For example, a decision by Laois County Council or Longford County Council to develop a strong policy of waste elimination, with clear objectives and ambitious targets for repair, re-use and recycling, could be over-ruled on the basis that any such objectives were not consistent with those in the Eastern and Midland Regional Waste Management Plan. To consider another example – if Westmeath or Longford County Council were to refuse planning permission for a hazardous waste processing facility on the grounds that it would not be compatible with the County Development Plan for the relevant county, could Dublin City or County Council make a successful appeal to An Bord Pleanála on the grounds that the provision this facility was part of the Regional Waste Management Plan ? We have seen how Dublin City Council has been prepared to use its muscle in order to abstract water from the River Shannon instead of focusing its efforts on leakage control, demand management and other water saving measures. Giving Dublin City Council and the other local authorities in the Greater Dublin Area power to set waste policy in an area encompassing some twelve counties is, in our view, an inappropriate and retrograde step. !Dublin’s track record in the past regarding the promotion of incineration rather than zero waste, is a cause of worry to those communities outside of Dublin who have landfills and incineration already imposed on them. Furthermore, the way in which Dublin City Council has promoted incineration, and has entered into a widely criticized contract with an incinerator operator which will result in an extremely heavy cost burden to Dublin’s citizens into the future, increases our reason for concern. As the members of the City Council are only too well aware, the size of the proposed incinerator, the cost of the project to date, and the terms of the contract have been the subject of justified criticism by a very significant number of environmental organisations and residents of Dublin, and by the European Commission. It may also be appropriate to refer to the judgement of the High Court in the case taken by Panda Waste and others against Dublin City Council in 2009, when Mr Justice Liam McKechnie found that Dublin City Council abused its dominant position in the capital's waste market, and he ruled that the local authority's decision to change the capital's waste collection system is invalid. The Court also concluded that an earlier review of the city’s waste, undertaken by the Council, was prejudged and the outcome predestined. The above events do not inspire confidence in Dublin City Council’s ability to take on the role of Regional Waste Co-ordinator, and to manage waste and


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control waste collection and disposal of the wide area of 12 counties proposed in the new waste management regional policy. Our further concern is that the expansion of Dublin’s waste management policy into Leinster will not be about creating a greater market for creating jobs in waste resource management, repair, reprocessing or recycling - we fear that it will primarily provide a justification for the extension of landfill facilities and the expansion of the capacity of the incinerator operated by Indaver at Carranstown near Duleek. Our final concern is that these large “waste management regions” may be a stepping stone towards the installation of large-scale incineration facilities in all three regions. While we have no direct evidence for this, we can find very little other justification for the establishment of such areas. On the other hand, it is clear that giving Dublin City Council control over potentially much larger sources of waste would strengthen the Council’s intention to pursue incineration as the primary method for dealing with waste. !3. ZWAI POLICY ON WASTE AND THE MANAGEMENT

OF WASTE !As a background to addressing in detail the Eastern & Midlands Draft Regional Waste Management Plan 2015 – 2021, we wish to describe our policy on waste generation and elimination, and on re-use, repair, recycling and disposal. Our belief and approach is that waste management must not rely on landfills, incineration, so-called “waste-to-energy” solutions, or any other “end-of-pipe” approaches. Future waste management must recognise that:

! While land filling may have to remain an acceptable means of dealing in the short term with locally generated residual quantities of non-recyclable and non-compostable municipal solid wastes, the only long-term sustainable solution is to completely eliminate the production and sale of materials in the economy which cannot be re-used, recycled or naturally biodegraded;

! Instead of organising systems that efficiently dispose of or recycle our wastes, we can and must learn from nature to design systems of production and consumption that have little or no waste to begin with -- this will result not only in a saving of scarce resources, but will re-adjust our relationship to the earth’s material assets from a linear to a cyclical one, enhancing our ability to live comfortably while reducing environmental damage;


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! The only long-term sustainable solution to municipal, industrial and agricultural waste management is to eliminate the production of materials which are toxic and which cannot be naturally biodegraded, re-used, recycled or re-processed as secondary raw materials for other productive industrial or commercial uses;

! “Zero Waste” is an integrated realistic whole-system approach to addressing the problem of society’s unsustainable resource flows – it includes waste elimination at source through product design and producer responsibility, together with waste reduction strategies further down the supply chain such as cleaner production, product dismantling, recycling, re-use and composting; and,

! The implementation of “extended producer responsibility” on all section of Irish Industry is a key requirement for the achievement of Zero Waste.

Practical steps towards achieving the goal of Zero Waste should focus on solutions that are being put into practice in many countries, including examples of clean industrial production, waste elimination, successful recycling and “zero waste” practices worldwide. Achieving this goal does not require complex or advanced technology solutions, only the realisation and full understanding that:

" Waste is made by mixing a variety of discarded materials; therefore segregation at source is an essential pre-requisite to sustainable waste management;

" It is essential that waste is considered as a community resource, and not as a bulk commodity to be removed by disposal to landfill or by incineration;

" Communities should be encouraged to handle their discarded materials responsibly;

" Communities cannot resolve the waste problem alone and should not be forced to clean up after irresponsible industries;

" Countries and communities faced with discarded materials and objects they cannot reuse, recycle or compost have to demand that industry stops producing them; total recycling is not approachable without industry's willing cooperation;

" Sustainable waste management or “Zero Waste” combines community practices such as reuse, repair, recycling, toxic removal and composting, with industrial practices such as eliminating toxics and re-designing packaging and products for the environmental and ecological demands of the 21st century;

" Sustainable waste management brings together the need to develop sustainable communities and sustainable industry and business; and,


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" Sustainable waste management or “Zero Waste” combines ethical practice with a solid economic vision, both for local communities and for local and national businesses. On the one hand, it creates local jobs and small scale enterprises, which collect and process secondary materials into new products, and on the other hand, it offers major companies a way of increasing their efficiency, thereby reducing their demands on virgin materials as well as their waste disposal costs.

Appropriate fiscal (taxation), economic and social incentives are the key to the creation of the necessary structural and behavioural changes, and they should be introduced without delay. Such incentives have been recommended to the Irish Government by the European Commission, the Organisation for Economic Cooperation and Development (OECD) and by the Economic and Social Research Institute (ESRI) – yet they have not been implemented, and the reasons for this failure of approach must be examined, and the barriers to implementation removed. 4. IMPLEMENTING THE CIRCULAR ECONOMY !The “zero waste” approach to the management of waste is based on eliminating as far as possible the production of materials and objects which cannot be repaired, re-used, recycled or naturally biodegraded at the end of their useful lives. Government policy should focus on negotiating with our European partners for the banning of products and materials within the community that cannot be recycled or that do not meet with the minimum requirements of achieving a circular economy This approach is consistent with the concept of the “Circular Economy” which is base on ideas first developed by Walter R. Stahel in 1982, when he visualised an economy as a series of closed loops, driven by private sector innovation and resulting in resource savings, waste prevention and job creation. German chemist Michael Braungart and American architect Bill McDonough further developed this vision to produce the “Cradle to Cradle” concept – a design philosophy which considers that all products of industrial processes can be re-used as raw materials for further production, i.e., a continuous recovery and reutilisation of industrial materials. An essential part of the “Cradle to Cradle” approach is that the concept of waste is eliminated; products and materials are designed for almost perpetual reuse, so that potentially valuable materials can be collected and recovered in life-cycles safe for human health and the environment. We would emphasise that this concept is quite different from “Cradle to Grave”, which is characteristic of the linear economy, in which raw materials are


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transformed into products which eventually end up as waste (see figure 1 below). This policy is also consistent with the Government's current waste management policy – “A Resource Opportunity” – which aims to maximise the resources that can be recovered from waste, using the most appropriate technologies. “A Resource Opportunity” does not explicitly mention the circular economy, but it is based on the EU waste hierarchy and encompasses a range of measures across all 5 tiers in the hierarchy; namely, prevention and minimisation, reuse, recycling and recovery of energy.2

Figure 1: The “Linear Economy” and the “Circular Economy” The policy also states that reuse and preparation for reuse will be encouraged and promoted through the renewed national waste prevention programme, so as to facilitate the reuse of unwanted goods between businesses and between members of the public.3 The Eastern and Midlands Draft Regional Waste Management Plan 2015 – 2021 also shows a significant and very welcome change in policy direction towards the concept of the circular economy, and the Plan refers to “A Resource Opportunity” as “the Government’s blueprint for a circular waste economy”. Apart from the fact that the expression “circular waste economy” is a contradiction in terms, the plans include targets which, if they are achieved, will

2 "A Resource Opportunity - Waste Management Policy in Ireland". Published by the

Department of the Environment, Community and Local Government, July 2012; Foreword, page 3.

3 "A Resource Opportunity - Waste Management Policy in Ireland". Published by the Department of the Environment, Community and Local Government, July 2012; page 10.


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underpin “the transition towards a circular economy and will be a stepping stone for further progress”.4 These targets take their lead from the European Commission’s proposals which emphasise the circular economy as a means of pushing the boundaries of recycling in all Member States. As proposed by the EU, and taken up as a strategic approach and vision for regional waste management in Ireland, the circular economy model fundamentally considers waste as a valuable resource to be recirculated into systems of near-continuously maintaining, repairing, reusing, refurbishing and recycling materials and products. The existing make-take-dispose linear models where products having reached their end of life are discarded as waste are no longer viable. For the current linear approach to continue and thrive it assumes resources are plentiful and will constantly be available at low cost prices to meet demand. The economic reality is very different.5 On 02 July 2014, the European Commission adopted the Communication “Towards a Circular Economy: A Zero Waste Programme for Europe”, the purpose of which is to establish a common and coherent EU framework to promote the circular economy.6 A very similar policy had earlier been advocated by the European Commission under the title of “Industrial Symbiosis”, whereby different participants derive mutual benefit from sharing utilities and waste materials, with the aim of turning waste from one industry into useful feedstock for another one. Secure access to resources has become an increasingly strategic economic issue, while possible negative social and environmental impacts on third countries constitute an additional concern. Improving the re-use of raw materials through greater 'industrial symbiosis' (where the waste of some firms is used as a resource for others) across the EU could save €1.4bn a year and generate €1.6bn in sales.7 The European Commission has also pointed out that management of secondary raw material flows requires reliable and harmonised data for the estimation of

4 Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021; section 5.4.2

(Performance Targets), page 45. Eastern‐Midlands Region Waste Management Office, Dublin 8.

5 Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021; section 5.2 (Our Vision), pages 36-37. Eastern‐Midlands Region Waste Management Office, Dublin 8.

6 Towards a circular economy: A zero waste programme for Europe, 2014. Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions; Brussels, 2.7.2014 COM(2014) 398 final.

7 Roadmap to a Resource Efficient Europe; Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, 2011. Section 3.1.2 (Boosting efficient production), page 6. Brussels, 20.9.2011 COM (2011) 571 final.


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composition, patterns of supply and quantity of wastes generated over the year(s), in order to achieve reliable and predictable feed-stocks of secondary raw materials for industrial plants. Industrial symbiosis needs coordination between a variety of stakeholders, including industry, research institutions, civil society organisations, public authorities and policy makers, together with an increased awareness of producer responsibility for waste avoidance.8 The above topic was one of the principal research priorities identified in the EU Seventh Framework Research and Innovation Programme, 2007 – 2013, in the thematic areas of 'model business and consumer behaviour', 'product production design', and 'policy', which included sustainable lifestyles and consumption behaviour, sharing utilities and waste materials, producer responsibility for waste production, increased product life-spans, enabling material reuse, recycling, recovery, industrial symbiosis leading to closed-loop processes, and consumption behaviour and lifestyle change. It is now a major part of the Horizon 2020 work programme – the largest EU Research and Innovation programme ever with nearly €80 billion of funding available over 7 years (2014 to 2020) – in addition to the private investment which this EU funding will attract. It is therefore clear that the operational concepts of the “circular economy” and “industrial symbiosis” will replace the older and now outmoded linear model in which products are discarded as waste at the end of their life. When we classify discarded products and materials as waste, we almost automatically consider how they should be disposed of, an activity which always incurs a cost, even if the material or product may be recycled or some of its embodied energy recovered. ZWAI therefore fully supports the vision for a Circular Economy described briefly in the Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021, and would urge implementation of the following objectives: !

8 Horizon 2020 Work Programme 2014 – 2015; adopted on 10 December 2013. European

Commission Decision C (2014)4995 of 22 July 2014; Part 12. Climate action, environment, resource efficiency and raw materials -- Waste-1-2014: Moving towards a circular economy through industrial symbiosis; Page 8 of 88.


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5. CHARGING BY WEIGHT FOR WASTE, AN IMPROVED SYSTEM OF WASTE DISPOSAL LEVIES, AND BETTER FINANCIAL SUPPORT FOR RE-USE, REPAIR AND RECYCLING

!The Department of the Environment has announced recently that the collection and disposal of household waste will eventually be charged by weight, to help citizens to “improve the segregation patterns, recycle more and reduce their waste to further reduce their waste bills”. Waste collection companies will be required to offer a pay-by-weight billing system which would result in lower charged to customers who recycle and compost waste. Zero Waste Alliance Ireland fully supports pay-by weight, but we are concerned that there might be a public backlash against pay-by-weight for waste disposal if the system is not implemented transparently and efficiently. The example of how water charges were implemented and are being enforced, and the public response to them should provide a lesson to be learned. Public opinion could erroneously view that a waste charge would impact primarily on poorer people who could not pay, and therefore there would be a strong resistance to it. To counter this potential opposition, we recommend that the Government needs to be seen to be more pro-active in facilitating the public to achieve our resource recovery goals, and to provide appropriate financial incentives to help householders and small businesses. To be seen to be fair to all sectors of society we recommend that the Government should be seen to be pushing Corporate Ireland to contribute more, and to take further steps to achieve our resource recovery goals. Every citizen, business, corporation, industry, hospital or state regulation authority that plays a part in destroying finite resources, discards rubbish on the side of the road, discharges pollution into the ground water, emits pollutants into the atmosphere or locks society / economy into a habit of waste needs to change. To help implement the “charge by weight” policy and other resource recovery objectives and activities, we recommend that the Minister for Environment should also commit to adjusting upwards the State levies for other waste-related activities which are lower in the waste hierarchy. For example, the “highest” per tonne levy should be imposed on waste going to incineration, for the purpose of off-setting the environmental costs of incineration, the cost of the very necessary continuous local ambient air monitoring, and to help fund a resource recovery and reprocessing industry in Ireland. A slightly lower State levy, but not lower than at present, should be charged on waste to be deposited in mixed wet landfills, to fund the environmental remedial


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costs, and to fund a resource recovery, reprocessing, remanufacturing industry in Ireland. This amount of such a levy should also increase in future years as the options for segregation and recycling improve further. A levy lower than the two mentioned above should be imposed on residual waste being deposited in a small number of more environmentally appropriate landfills which accept only residual material that is dry, pre-screened and / or pre-composted, and which would give rise to no odour and no vermin. This levy should also be used to financially assist the establishment of infrastructure needed to encourage and support a circular economy. On page 13 of the Executive Summary, the draft Regional Waste Management Plan states that the funding requirement for litter and street cleaning is €70 million. If the plastic bag levy is to be judged as a success, we need to take further steps with plastic, glass and aluminum containers also. ZWAI recommends that the Regional Waste Management Plan should include an objective to establish money-back schemes for beverage containers, such as those practiced in many other European countries. Re-use of glass bottles should be encouraged by financial support being given for the establishment of regionally based glass bottle washing facilities, as these will create more jobs and use less fossil fuel energy. Such facilities could be developed and operated by the beverage industry, or by local businesses (some of which could be charitable operations) which would then supply the industry. It is our observation that this would be much more energy efficient than collecting glass (as broken glass cullet) from the four corners of Ireland and recycling it in a single facility. A money-back scheme for beverage containers would also greatly reduce the roadside litter problems shown in the photos below. If Nova Scotia can insist on having standard beer bottles that are washed and reused, then we should follow that example. ZWAI is anxious to see further progress being made in resource recovery, reuse and recycling with as little political reaction or controversy as possible. We support strategically focused waste charges as long as the income will be used to more quickly develop our resource recovery and recycling industry. We also need funding for the continuous measurement of ambient air pollution near existing waste management facilities. We recommend for example the simultaneous further taxing of those industries such as incineration and wet mixed landfilling as these activities are at the bottom of the waste hierarchy, they destroy resources, impact adversely on public health, and certainly do not contribute to a circular economy.


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To summarise, it is our observation and recommendation that higher levies on incineration and landfilling should be used to encourage the development of re-use industries. In addition to the pay-by-weight scheme as proposed, ZWAI supports other revenue-neutral taxes for similar environmental protection reasons to achieve additional environmental and employment goals. Proposed Virgin Material Tax We suggest that a new tax needs to be put on virgin raw materials. Ours is probably going to be the last generation that continues to be so thoughtless and indifferent to the imminent final exhaustion of our finite resources. These are the materials that will be reaching their world resource limits over the coming years or decades; which will not be available to future generations and are not replaceable. An effective economic advantage should be given to any of the re usable or recycled form of this material in order to encourage the circular economy that Europe wants us to adopt. Oil is the obvious big example of a strategically important resource that will shortly no longer keep up with world demand. The problem with the present tax on petroleum is that so little of this money is being strategically spent to reduce our dependency on this finite resource. Phosphorous is another example. World phosphorous rock resources are projected to become expensive as the resource starts to run out over the coming 2 or 3 decades. We need to impose a tax now to invest in the infrastructure to recycle phosphorous


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Plastic Type Labeling Tax A problem exists where the type of plastic in a container is so often not clearly marked or easily identified. At one public amenity centre in County Louth there is a skip for PE milk bottles, a second for PET lemonade bottles and a 3rd skip for a wide variety of mixed plastic containers. Ideally instead we should be facilitated to separate much more of the mixed plastic waste so that the over whelming portion of plastic containers are separated into their own plastic type. It takes too much time at present to make a close enough inspection of the plastic container to see if it is PE, PET, PS or PP. Taxes should be levied on all plastic containers that do not have a clear indication of the type of plastic so it can be more easily recycled. Financial Support for Recycling The finance section of the Executive Summary for the Eastern and Midland Region shows the funding requirements under the new plan, and it is clear that lowest amount of financial support is for recycling. It is our observation that it is neither credible nor honest of the State to be claiming to be supporting a circular economy while spending only €8 million for recycling out of a total spend in the waste sector of €118 million. The table of Infrastructure Element Costs provides the shocking disclosure that €260 million is projected to be spent by the private sector on thermal treatment of waste; but for reuse, reprocessing and pretreatment the estimated cost is not quantified. We ask why not? Is there not a need to spend as much or even more to develop the circular economy? 6. SEPARATION AT SOURCE – INTEGRATING

HOUSEHOLD WASTE SEGREGATION WITH THE BUILDING REGULATIONS

We have pointed out in section 3 above that ZWAI consider that “waste” is produced when a variety of discarded materials are mixed; and that therefore segregation at source is an essential pre-requisite to sustainable waste management. If the goal is to maximize segregation, we need to create a positive culture of resource separation at the earliest stage in the cycle; in the home. In Ireland, when designing new houses and apartments, almost no thought was put into planning for the management and separation of kitchen waste. With the current


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pressure from Europe to move to a circular economy we believe that Irish house design must facilitate this new culture and new thinking. We propose that the Technical Guidance Documents in the Irish Building Regulations would have a new section that encourages and facilitates home owners in this regard. While this is not strictly part of the draft Eastern and Midlands Regional Waste Management Plan, we believe that such a move could be given support by including it as an objective. Existing Resource Conservation and Recovery in Irish Building Regulations It’s worth noticing that we already have regard to the concept of resource conservation and recovery within the Irish Building Regulations. We have in Part L guidance for heat insulation which will help to conserve our oil imports. In Part H we have likewise been progressive, we now encourage rainwater harvesting as well as grey water segregation for treatment and recycling. We suggest that we should also positively facilitate solid waste recycling within the Building Regulations. The thrust of the wording for a new section in the Technical Guidance Documents would be as follows. Part N – Waste Resource Separation and Segregation In the Home Health protection The separation of kitchen and general household waste should be carried out in a manner that avoids human health hazards, prevents the attraction of rats or mice and minimises or avoids noxious odours. Formal early planning for resource separation in the kitchen When planning for a zero waste home, the planning for waste separation and storage at planning application stage should be undertaken. Facilities for the temporarily storage of kitchen waste should be provided for in all new kitchen designs in the same way as happens for cookers, fridges, dish washers etc. Architectural drawings in planning applications should show the location of the waste separation & storage cupboard within or directly adjacent to the kitchen. House plans from the architect should clearly show where in the kitchen the resource separation space is to be located. The resource storage facilities need to be carefully considered so that it is close enough to be practical for the person who is un-wrapping food and cooking the meal.


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Storage size Depending on family size a storage space volume of between 0.25 and 0.4 m^3 should be properly provided for integration inside kitchen islands, cupboards or purpose made presses. Where a number of deep drawers are being considered they must be of easily washable material such as polyethylene or polypropylene. No toxic plastic materials are to be recommended in contrast to other materials that are themselves not recyclable. PVC for example or other plastic materials comprised of chlorine or bromine should be avoided as they produce dioxins when burned or incinerated.

This self standing set of stacked plastic drawers in the photo is an example of a system that meets the requirements above. The drawers sit snugly in the frame so that mice cannot enter. The food waste bins on top have snap shutting plastic handles on the lids to keep in the smell of the waste food. The translucent drawers and the frame are of polypropylene plastic. The owner is able to wash the plastic surface every so often. Ideally however these drawers would be hidden from view behind the door of a press or cupboard. Most families nowadays prefer that cupboard shelves with cups and plates are hidden. For Longer Storage Periods The photo below shows how this particular family are able to visit the Public Amenity Centre less often.


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The self standing drawers are taken from the kitchen and each drawer is emptied into one of 6 small blue wheelie bins. They also have smaller plastic containers for batteries, bulbs, aluminium, CD’s etc. When full the six bins are taken in an open topped trailer to the Public Amenity Centre in Dundalk on about 7 occasions in the year. The cost is €2 for each visit so their overall annual cost is €14 / annum The Guidance Document should assist the family and the architect to plan for a 3 wheelie bin system or a larger system with more bins and better segregation as shown above. So often modern compact houses are built by developers to use the smallest footprint with no thoughtful planning for segregated solid waste management. Saving on the Pay by Weight charges by Composting Our proposal for a new Part N of the Building regulations should also offer guidance and minimal standards for home composting of organic kitchen waste. When composting the primary health protection goals are to avoid vermin and odours.


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Domestic Rotating Drum Composters Rotating drum composters like that shown in the photograph below are 900 mm long and 700 mm diameter, with 8 sides and 2 inches of insulation. It has two internal compartments. One is for filling and the other for composting. The outside body is of aluminium. It rotates on a horizontal shaft. The owner has it located near to the back door under a rain shelter to keep it dry. The Guidance Document would require the planned location of this composter The householder merely adds a few handfuls of wood pellets anytime she/he is filling with food waste. This type of composter usually becomes very warm and may steam with the heat that is generated inside it. The owner claims that with this rotating drum being up off the ground that she/he has never had any problem with rats. This is in contrast to a previous composter that sat on the ground and attracted rats.

Since food waste is relatively heavy, we believe that more people will begin to home compost to save on the pay by weight charges. The Guidance Document should advise people on the obvious pitfalls and the measures needed to avoid vermin and odour nuisances. It should advise on the space requirements and the protection that is needed from wet weather. The owner also advised that it should be higher off the ground so that a wheel barrow can be positioned underneath to collect and take away the finished compost.


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This is a now a mature technology. We recommend this is one type of composter that should be described in the Technical Document. We believe that people should have access to advice on this subject in the Building Regulations as a way to reduce the weight of their bins being collected. Domestic Vermicomposting Vermicompost is the product or process of composting using particular species of worms.

This self standing drum system has three removable trays for the food waste and worms. It measures 470 mm diameter and the body is 430 mm tall. It stands on 5 plastic legs. Earth worms consume waste food that is not acid such as orange skins and onions. Relative the rotating composter it is therefore slightly more restricted with the waste food that it will accept, but for small families its compact size has some advantages.


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7. PUBLIC CONSULTATION !!It is our submission that the consultation process is inadequate and does not conform to the most basic principles of the Aarhus Convention, for the following reasons:

• It is unclear whether the Department of Environment, Community and Local Government or Dublin City Council are driving this draft Regional Waste Management Plan and other regional waste management plans, together with the changes in the areas and numbers of waste management regions;

• There had been no real public consultation about the policy change which could directly affect many people whose waste is collected by private companies operating in any or all of the counties listed in the notice;

• There appears to be no opportunity for any participation in the decision-making process, in further contravention of the principles laid down in the Aarhus Convention.

• No information is given of the various separated resources being

collected at Public Amenity Centres. We don’t know the final destination of the materials being collected. We don’t have any analysis of the Irish jobs being supported in the handling, transport, reprocessing, or re- manufacure.

!!!!

Ollan Herr Jack O’Sullivan

On behalf of Zero Waste Alliance Ireland. !!30!January!2015!!!!!!!!!!!

ZWAI Submission on draft EastMidRegWasteManPlan, draft 3, 30-Jan-15.doc

Appendix(I(

Notice(on(the(website(of(the(Department(of(the(Environment,(Community(and(Local(Government(inviting(Comments(on(the(draft(Regional(Waste(Management(Plans

RE: Observations by Zero Waste Alliance Ireland on the draft Regional Waste Management Plan for the Eastern & Midlands Region.

EMWR <[email protected]> 5 February 2015 at 14:56 To: Jack O'Sullivan <[email protected]> Cc: Hugh Coughlan <[email protected]>

Dear%Mr.%O'Sullivan, Please%note%your%submission%was%received%on%the%30th%Jan%2015;%and%whilst%your%submission%will%be%read%there%is%no%statutory%obligation%to%consider%the%content%when%plan%amendments%are%being%considered. Regards, Emma Cassin |Project Co-ordinator| Eastern & Midlands Regional Waste Management Plan | |Dublin City Council | Eblana House | Marrowbone Lane, Dublin 8, Ireland | T +353 1 222 4312| F +353 1 411 3440 | [email protected] | www.emwr.ie

Smaoinigh ar an timpeallacht sula ndéanann tú an ríomhphost seo a phriontáil. Please consider the Environment before printing this mail.!

From: Jack O'Sullivan [[email protected]] Sent: 30 January 2015 15:05 To: EMWR Subject: Observations by Zero Waste Alliance Ireland on the draft Regional Waste Management Plan for the Eastern & Midlands Region.

Regional Waste Coordinator, Eastern & Midlands Region Waste Management Office, Block 1, Floor 6, Civic Offices, Dublin 8.

Dear Sir,

Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021 Submission to the Eastern & Midlands Regional Waste Coordinator On behalf of Zero Waste Alliance Ireland (ZWAI), I am attaching an electronic copy of our observations on the draft Eastern & Midlands Regional Waste Management Plan 2015 – 2021, together with our covering letter to you. Yours sincerely, Jack O'Sullivan Zero Waste Alliance Ireland

Appendix(II Acknowledgment(received(from(Dublin(((((((((((((((((((((((((((((((((((City(Council(on(05(February(2015

************************************ Environmental Management Services Aplinkos Apsaugos Konsultacijos Comhairleoirí Comhshaoil Environmental and Planning Consultants Outer Courtyard, Tullynally, Castlepollard, County Westmeath, Ireland. Loc8 Code: MJM-20-W96 Telephone +353 44 966 2222 Fax +353 44 966 2223

E-mail [email protected]

*************************************

ZWAI-E&MRWMP-005 Email acknowledgement from Dublin City Council, 05-Feb-15.doc

ZWAI-E&MRWMP-012a Complete Submission on draft EastMidRegWasteManPlan, 30-Jan-15

Documents

Transcript of ZWAI-E&MRWMP-012a Complete Submission on draft EastMidRegWasteManPlan, 30-Jan-15