Narrow window – opportunity for even further improvement??
Consultation on Section 60 Policy Direction on a proposed cap to incinerationcapacity as a proportion of municipal waste arisings (MSW) and other matters.
The Minister for the Environment, Heritage and Local Government recently arranged for environmental consultants to prepare an Environmental Report, according to Strategic Environmental Assessment requirements, to inform the policy making process for waste management in respect of a proposed Section 60 policy direction to achieve the following objectives:
1) to ensure that incineration capacity does not reach a level such that waste is drawn to incineration which could have been dealt with by prevention, reuse, recycling, composting/anaerobic digestion of source segregated biowaste, MBT or other methods higher up the waste hierarchy;
2) to ensure that the waste hierarchy is complied with in that local authorities, as waste management authorities, do not direct holders of waste to deliver it to lower elements in the waste hierarchy, thereby preventing them acting in support of waste management options at the bottom of the hierarchy;
3) to ensure that the waste hierarchy is complied with in that local authorities, as waste management authorities, could direct holders of waste to deliver it to higher elements in the waste hierarchy, thereby encouraging them to act in support of waste management options at the top of the hierarchy;
4) to minimise the air pollution arising from trucks accessing waste facilities in built up areas;
5) to ensure appropriate monitoring of air pollution in the vicinity of major waste facilities;
6) to reduce air soil and water pollution from incineration and comply with the Stockholm Convention
In advance of finalising the Strategic Environmental Assessment comments on the report’s recommendations are invited from relevant stakeholders and any other interested parties.
Comments should be submitted by email or by post to the address below and before Friday 17 July 2009.
by email: evelyn_downes@environ.ie
by post: Ms. Evelyn Downes,
Waste Policy: Review and Regulation Section,
Department of the Environment, Heritage and Local Government,
Custom House, Dublin 1.
Please note that all submissions and comments submitted to the Department of the Environment, Heritage and Local Government for this purpose are subject to release under the Freedom of Information Acts 1997 and 2003.
Full report available from http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/File
DownLoad,20552,en.doc
UKWIN Consultation submission:
Thursday 16th July 2009
Dear Ms Downes
Thank you for this opportunity to comment on the Section 60 Policy Direction on a proposed cap to incineration capacity as a proportion of municipal waste arisings (MSW) and other matters. My submission to this consultation is made on behalf of United Kingdom Without Incineration Network (UKWIN), in my capacity as the National Coordinator of UKWIN. I have read the Environmental Report (ER) prepared for the Minister for the Environment, Heritage and Local Government, in accordance with Strategic Environmental Assessment requirements, and I would like to make some comments arising from both the summary of objectives and the more comprehensive ER.
1. Drawing on experience of waste management strategy and practice in the UK, I wish to emphasise the importance of stating the obvious. The first 3 Objectives, regarding the waste hierarchy, are therefore necessary, despite the impression that their explicit statement might be seen as somewhat repetitive and self-evident.
2. It is certainly the case that in the UK, despite policy statements to the contrary, incineration disrupts attempts to manage waste in accordance with the waste hierarchy. As the Coordinator of UKWIN I receive reports from throughout the UK highlighting the ways that discarded materials, such as kitchen waste and a variety of plastics that could be composted or recycled are instead relied upon to maintain the ‘required’ levels of feedstock for existing waste incinerators. In situations where waste has not arisen as predicted, instead of celebrating the success in managing waste in accordance with the waste hierarchy (by reducing waste arising), the local authorities and operators talk about a ‘shortfall’.
3. Attempts to meet this shortfall in incinerator feedstock, by substituting household waste with commercial and industrial wastes, have resulted in inefficiencies. These inefficiencies, for example in Sheffield, have led at least one major operator (Veolia, formerly Onyx, formerly Vivendi) to apply for a variation in planning conditions to allow household waste to be transported longer distances merely to enable the incinerator to operate in more commercially advantageous ways (see Veolia’s application to Sheffield City Council to vary Condition 3 of permission 01/10135/FUL, associated with their Bernard Road incinerator, to allow household waste to be brought in to Sheffield from Barnsley, Doncaster and Chesterfield and to increase the waste collected outside Sheffield to 75,000 tonnes).
4. Even when Veolia incinerates 70% of Sheffield’s waste, they are still obliged to chase waste from Barnsley, Doncaster and Chesterfield to feed the facility for economic reasons, i.e. to protect their profits. It should be noted that, according to Veolia’s annual performance report for 2007 (available from http://www.ukwin.org.uk/files/pdf/sheffield2007.pdf), “During 2007 the facility processed 196,505 tonnes of waste, of this 67.85% was domestic waste collected by Veolia from the residents of Sheffield, the remaining 32.15% came from commercial premises.” Therefore, it is reasonable to assume that if the planning condition is varied, only about half of the waste incinerated in Sheffield will originate from Sheffield’s residents. Furthermore, recycling and composting rates for Sheffield remain depressed, never rising above 28%, whilst incineration reached 70% in the last quarter of 2008.
5. Thus, in the UK, incineration appears to be driving waste management away from reuse, recycling and composting, and towards violating the proximity principle. This ‘competition’ for waste is confirmed in research supporting a very recent consultation issued by Department for Energy and Climate Change (DECC), on Renewable Electricity Financial Incentives [ http://www.decc.gov.uk/Media/viewfile.ashx?FilePath=Consultations%5CRenewable%20Electricity%20Financial%20Incentives%5C1_20090715135352_e_@@_RelateddocElementPoyryreportonquantitativeissuesinFITsdesignFINAL.pdf&filetype=4 which says:
“The resource for electricity generation from waste is constrained by the amount of suitable waste. Incineration and advanced thermal treatment plants are more versatile can treat any carbon rich waste, including plastics, and hence is more versatile than AD which can only treat biological waste. In addition, other non-electricity technologies such as mechanical biological treatment (MBT), recycling, and composting compete for waste that is not sent to landfill”. (our emphasis)
This affirms the need to clearly state the obvious, as per Policy Direction Objectives 1– 3, and indeed Objectives 4 – 6 as well.
6. Although the national UK waste statistics distorts the localised picture (as not all Authorities rely on incineration), it is clear that in areas with existing incinerators, incineration capacity has already reached levels such that “waste is drawn to incineration which could have been dealt with by prevention, reuse, recycling, composting/anaerobic digestion of source segregated biowaste, MBT or other methods higher up the waste hierarchy”.
7. Monitoring requirements should be accompanied by enforcement requirements.
8. The importance of treating waste in accordance with the proximity principle should also be made explicit.
9. An additional Policy Direction Objective could be introduced to specifically aim to reduce, and aspire to eliminate, the production of hazardous waste through waste management methods, e.g. incinerator ashes.
10. Whilst recycling is important it is vital that further emphasis should be placed on the importance of waste reduction as the primary means of achieving the Policy Direction Objectives. To this end, ambitious statutory targets for waste reduction should be set. It should be made clear that waste reduction must be prioritised over and above even recycling and composting! It is interesting to note in this context that Denmark, with the highest level of incineration in the EU also has the highest per capita waste arisings [see Eurostat News Release “Half a ton of municipal waste generated per person in the EU27 in 2007” http://epp.eurostat.ec.europa.eu/cache/ITY_PUBLIC/8-09032009-BP/EN/8-09032009-BP-EN.PDF. Furthermore it can be noted that the Danish approach, with 53% incineration (424 kg/capita which is more than the ENTIRE waste arisings in five member states) leaves an absolute maximum of 47% for recycling and thus clearly constrains recycling and composting to below the levels reported in Belgium (62%); Germany (64%); Netherlands (60%); Austria (59%); Sweden (49%). England and Wales have targets for waste, albeit long term, to reduce the impacts to a fair ‘earthshare’. The current national waste strategy consultation for Wales ( Towards zero waste http://wales.gov.uk/docs/desh/consultation/090429wasteconsultationen.pdf) shows that to reduce the Ecological Footprint to sustainable levels even by 2050 will require a further reduction in the footprint, on top of the current recycling targets, of:
* Municipal waste - 34% by 2025 and 65% by 2050.
* Commercial and Industrial waste - 39% by 2025 and 69% by 2050
* Construction and Demolition waste - 28% by 2025 and 59% by 2050
This can be seen in the supporting report “Ecological Footprint impact of the Welsh Waste Strategy” (http://wales.gov.uk/docs/desh/consultation/090429wasteecologicalfootprinten.pdf ). The scale of the waste reduction necessary is perhaps best illustrated by a graph from that document:
[visit http://wales.gov.uk/docs/desh/consultation/090429wasteecologicalfootprinten.pdf for graph]
Although direct comparison is difficult because of the different ways in which some commercial wastes are measured in the municipal waste totals the reductions necessary in Ireland may be even greater than in Wales.
Ireland should therefore set ambitious targets for the reduction of both the total volume of municipal waste arising and the total volume of household waste per capita. These targets should be reassessed on an ongoing basis, with short intervals between targets so that they remain meaningful and ambitious. I would hope that Ireland would aspire to true sustainability well before the 2050 target proposed by Wales. This is conveniently beyond the term of office of current politicians and is thus a meaningless date save that it implies a political acceptance that Wales will remain unsustainable for at least a further four decades. Ireland can surely do better!
11. If the intention is to reduce dependence on incineration, a policy that UKWIN would obviously endorse, then the <30%/25% by 2015 target should be accompanied by a commitment to continuously reduce dependence on incineration from its current level. The current levels of incineration should be seen as a ‘peak’, and the policy should make explicit that no additional incineration facilities should become operational, and no additional capacity should be allowed.
12. Consideration should be given, where appropriate, to season variation – the prospect of ‘seasonal shortfalls’ of incinerator feedstock highlight the inflexibility of incineration as a method for managing waste.
13. The ER does a good job of explaining uncertainties associated with waste projections. One further aspect of this situation worthy of consideration is the benefits to be derived from making all modelling assumptions (e.g. source data, formulas, etc.) readily available to the public so as to allow meaningful critique and continuous improvement to the waste modelling and associated projections.
14. Proposals for the introduction of an incineration levy, together with stringent controls on incineration, are heartily endorsed, and UKWIN urges Ireland to set a good example for its neighbours in this respect as promptly as possible.
Thank you for your consideration,
Shlomo Dowen
United Kingdom Without Incineration Network (UKWIN)
National Coordinator