environmental pillar submision to the regional waste...

Environmental Pillar Submission to the Public Consultation on the Regional Waste

Management Plan January 2015

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ENVIRONMENTAL PILLAR

SUBMISSION TO THE

REGIONAL WASTE

MANAGEMENT PLAN

January 2015



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Contents

1. Introduction 3

2. Recommendations 5

3. Reduce Landfilling to only residual waste 7

4. Zero Waste 8

5. Prevention 9

6. Source segregation 11

7. Energy Recovery is limited to non-recyclables 13

8. Inefficiency 14

9. Alternatives, job creation and market risks 15

10. Environmental and health impacts 17

11. Recycled Waste is used as a reliable source of raw material 18

12. Industrial symbiosis 19

13. Monitoring and Enforcement 22

14. Food Waste is reduced 22

15. Biowaste treatment 22

16. AD plants internationally 24

17. Reviews of existing product and waste legislation 24

18. Increase public information campaigns to stimulate a change in behaviou 25

Appendix A ZERO WASTE PROPOSAL 27

Appendix B Proposal for a Pilot Deposit Refund Scheme (DRS) in Ireland 30



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1. Introduction

Ireland has made great strides in collection and recycling of waste since the mid-1990s,

where there was no kerbside collection on the Island. Since then, 72% of the country has

kerbside collections to support the management of household waste and most of this is

done through private waste management companies. However, rural areas, primarily in the

Southern Region and the Connacht Ulster Region, have no kerbside service. Because of the

population variances and the unknown number of households in each region, we cannot

extrapolate a proper national figure. The chart below outlines the current waste service

levels within each waste management region in 2012:

Region % households

with kerbside

service

% households

without

kerbside service

% kerbside

services with 2

bin collection

% kerbside

services with 3

bin collection

Eastern

Midlands

81% 29% 49% 46%

Southern 67% 33% 71% 27%

Connacht Ulster 58% 42% 70% 22%

Because there are still so many households not covered by kerbside collection, the residual

amount of waste is still high. And since there is no adequate reporting of how much of the

‘recovered’ waste is burned or recycled, it is difficult to determine how to change behaviour

and where contamination of the recyclates is done.

The EU has proposed a new waste and circular economy package, Towards a circular

economy: A zero waste programme for Europe, which has among its initiatives:

• the elimination of landfilling of recyclable waste by 2025 and an overall ban on

landfilling by 2030;

• achieving a recycling and preparation for re-use of municipal waste of 70% by 2030;

• a packaging waste recycling rate of 80%, with interim targets of 60% by 2020 and

70% by 2025;

• separate collection of biowaste by 2025;

• reduction of food waste by 30% by 2025;

• reduction in the use of plastic bags; and

• the establishment of a national data base for all waste statistics.1

The EU’s 7th Environmental Action Programme (7EAP), adopted by the European Parliament

and Council, also sets out the outline for future European environmental policy until 2020.

In terms of waste management and the circular economy, Member States should

“fully implement[ing] Union waste legislation. Such implementation will include

applying the waste hierarchy in accordance with the Waste Framework Directive and

1 European Commission Communication: ‘Towards a circular economy: a zero waste programme for Europe’,

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52014DC0398



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the effective use of market-based instruments and other measures to ensure that:

(1) landfilling is limited to residual (i.e. non-recyclable and non-recoverable) waste,

having regard to the postponements provided for in Article 5(2) of the Landfill

Directive; (2) energy recovery is limited to non-recyclable materials, having regard to

Article 4(2) of the Waste Framework Directive; (3) recycled waste is used as a major,

reliable source of raw material for the Union, through the development of non-toxic

material cycles; (4) hazardous waste is safely managed and its generation is reduced;

(5) illegal waste shipments are eradicated, with the support of stringent monitoring;

and (6) food waste is reduced. Reviews of existing product and waste legislation are

carried out, including a review of the main targets of the relevant waste directives,

informed by the Roadmap to a Resource Efficient Europe, so as to move towards a

circular economy; and internal market barriers for environmentally-sound recycling

activities in the Union are removed. Public information campaigns are required to

build awareness and understanding of waste policy and to stimulate a change in

behaviour.”2

Contact information:

For further details please contact Michael Ewing, Coordinator of The Environmental Pillar.

Postal Address: Environmental Pillar of Social Partnership. Knockvicar, Boyle, Co

Roscommon

Telephone: 00353 (0)71 9667373

Mobile: 00353 (0)86 8672153

Email: [email protected]

This submission was developed using the Environmental Pillar processes but is not

necessarily the policy of each member group in the pillar.

Environmental Pillar members: An Taisce. Bat Conservation Ireland, BirdWatch Ireland. CELT

- Centre for Ecological Living and Training. Coast Watch. Coomhola Salmon Trust. Crann.

ECO UNESCO. Feasta. Forest Friends. Friends of the Earth. Good Energies Alliance Ireland.

Global Action Plan Ireland, Gluaiseacht. Hedge Laying Association of Ireland. Irish Doctors

Environment Association. Irish Natural Forestry Foundation. Irish Peatland Conservation

Council. Irish Seal Sanctuary. Irish Seed Saver Association. Irish Whale and Dolphin Group.

Irish Wildlife Trust. The Native Woodland Trust. The Organic Centre. Sonairte. Sustainable

Ireland Cooperative. VOICE. Zero Waste Alliance Ireland

2 EU 7

th Environmental Action Programme, http://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX:32013D1386



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2. Recommendations

1: To create an effective database, the ultimate treatment of waste streams

should be properly categorised as 1) reused; 2) recycled; 3) used for thermal

treatment; 4) incinerated without energy recovery and 5) landfilled. The term

recovery which refers to recycling and energy recovery should be discarded as

an over-arching definition.

2: To create an effective database, the ultimate treatment of waste streams

should be properly categorised as 1) reused; 2) recycled; 3) used for thermal

treatment; 4) incinerated without energy recovery and 5) landfilled. The term

recovery which refers to recycling and energy recovery should be discarded as

an over-arching definition.

3: We propose that the target for waste prevention be increased to 2% per

capita per year and funding for prevention activities, public awareness.

4: We also propose the adoption of the economic instruments detailed above.

5: The adoption of a kerbside sorted system of collecting recyclable materials

to guarantee a higher quality of feedstock. However, if trucks are not easily

retrofitted to add more compartments, we recommend a 2-stream

commingled system of dry recyclate over a single stream. Separating paper

and card from metal and plastic containers would yield a higher quality of

paper material. Additionally, all households and food businesses must have an

additional bio-waste bin for separate collection.

6: A change in waste policy to move away from incineration/waste to energy as

a waste treatment technology and to move towards the adoption of ‘zero

waste’ principles.

7: Develop closed loop policies for all materials streams, with labour intensive

recycling as a priority.

8: Introduce deposit-and-refund schemes on all recyclable drinks containers on

a pilot basis to test the validity of extending the scheme nationally. See

Appendix B.



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9: Prioritise the implementation of the Food waste regulations and to

investigate the use of surplus edible foods currently discarded as waste.

10: Promote the development of anaerobic digestion of biowaste streams at

community level to deliver combined heat and power and to recycle nutrients

to the soils from whence they came.

11: We propose the establishment of regional and/or national symbiosis

programmes to foster and assist in the development of industrial symbiosis

networks.

12: There must be adequate and sufficient funding for local and regional

authorities to monitor and enforce the proper management and treatment of

waste to ensure that the waste hierarchy is properly enshrined in the ultimate

use of valuable waste resources.

13: Increase the REFIT rate for anaerobic digestion to encourage the

development of this industry and provide government assistance in terms of

grants, loans or guarantees.

14: We propose that the regional authorities investigate possible financing

mechanisms through the packaging PRI to fund the management of packaging

waste found in street cleanings, litter collections and street bins. Such funding

could also be used to provide increased number of separate recycling bins on

streets.

15: We encourage the regions to increase the amount of money available for

local waste prevention programmes, similar to that adopted by Zero Waste

Scotland. We also advocate for a more bottom-up public

awareness/community involvement to assist in behavioural change in how we

manage our waste.



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3. Reduce Landfilling to only residual waste

Historically, Ireland has relied heavily on the use of landfills to manage most of its waste

needs. Since 2012, the country has landfilled less than 50% of its waste, which is a huge

improvement. However, we must not substitute one disposal technology for another one,

namely incineration or waste-to-energy (WtE) plants. Currently, Ireland is burning over

321,000 tonnes of municipal waste domestically in the Meath WtE plant, cement kilns and

industrial incinerators and is exporting 842,635 tonnes (35% of managed municipal waste)

of which 300,000 tonnes (or 20% of our residual waste market) is send for ‘energy recovery’

or ‘thermal treatment’. Most of this exported waste is being burned in WtE plants

throughout Europe in Denmark, Germany and the UK, among other countries. As much of

the reported ‘recovered’ waste does not differentiate between recycling and thermal

treatment, it is difficult to calculate the hard numbers.

Instead of increasing our recycling rate, Ireland seems to be sending waste as Separated

Derived Fuel (SRF) or Refuse Derived Fuel (RDF) to WtE plants. Worrying statistics from the

plans show that the amount of Mixed Dry Recyclables (MDR) decreased by 3.2% between

2011 and 2012. Additionally, the plan states that the 15% increase in plastic packaging

recovered primarily reflects strong growth in Refuse Derived Fuel (RDF) as feedstock in

thermal treatment plants. The plan further reveals that subsidies for over 87,000 tonnes of

RDF were funded by Repak from contaminated paper and plastic, representing an increase

of 56% in 2012 vs. 2011. Of the 669,000 tonnes of packaging waste recovered by Repak in

2012, 87,000 tonnes went into RDF from contaminated paper and plastic (13% of packaging

collected).

There was a 2.5 increase in the amount of RDF and SFR diverted to energy recovery from

2010 to 2012 (94,174 – 230,399 tonnes) and an 11 times increase in the amount of residual

municipal waste going to energy recovery from 2010-2012 (19,293 – 244,334 tonnes) The

total amount going towards energy recovery for 2012 is 474,733 tonnes.

Future data must determine 1) what is the quality of the recyclables reclaimed from residual

waste and how much is reclaimed; 2) how much of the waste collected through street

cleaning and bin collection is recycled and how much is sent for energy recovery, 3) what

percentage of the MDR sent to Mechanical Recovery Facilities (MRFs) is contaminated and

ultimately sent on to incineration.

Recommendation 1: To create an effective database, the ultimate treatment of waste

streams should be properly categorised as 1) reused; 2) recycled; 3) used for thermal

treatment; 4) incinerated without energy recovery and 5) landfilled. The term recovery

which refers to recycling and energy recovery should be discarded as an over-arching

definition.

The key element to reducing residual waste is managing it through separate collection and

treatment of waste, reusing and recycling as much as is feasible and investing in technology



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and plants to sort and process recyclables. From the numbers in the proposed waste plans,

we calculate that the municipal waste amount per capital is 588 kg, with 255 kg recycled

and 333 kg residual. While this is less than Denmark at 718 kg per capita, it is well above

what is being achieved in zero waste communities around Europe (circa 350 kg/person with

80% recycled). See chart below.

2012 National Municipal

Waste Figures

Amount (tonnes) Per capita % of total waste

Residual waste 1,523,577 333 57%

Thermal treatment in Ireland 296,000

Landfilled 1,027,577

Thermal treatment abroad 200,000

Recycled/composted 1,168,960 255 43%

Total Municipal Waste 2,692,537 588 100%

As we move forward to make Ireland a resource efficient economy and to calculate where

we need to go, we must refer back to the EU for our future direction.

As the EU Commission communication on the circular economy package states, we need to

move towards a ‘zero-waste programme for Europe’.

4. Zero Waste

Zero waste is a journey towards a zero incineration and landfill society where waste is

considered a valuable resource rather than something to be buried or burned. The

traditional waste management in the EU28 is through disposal. Between 60-80% of waste is

disposed through landfill, incineration (with energy recovery, gasification, pyrolysis), and co-

incineration (cement kilns, and industrial furnace). Around 20-25% of waste is recycled, 5-

10% is composted and 5% is reused.3 Through a zero waste scenario, there is a move

towards resource efficiency and instead of a linear consumption model of extract, use and

then dispose, it adopts a circular economy model of cradle to cradle consumption where

there is no in-built obsolescence. In zero waste communities around the world, they

achieve:

• 10-20% residual waste,

• 30-35% recycling,

3 http://www.zerowasteeurope.eu/wp-content/uploads/2013/09/Introducing-ZWE-The-main-principles.pdf



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• 30-35% composting,

• 10-20% repair and reuse and

• 10-20% waste prevention

Communities such as Capannori and Priula in Italy, Gipuzkoa in the Basque Country in Spain

and San Francisco, CA in the US have adopted zero waste programmes by increasing their

recycling and composting collections and treatments, adopting ambitious waste prevention

actions, promoting economic incentives and investing in research and innovation.

In Ireland, our municipal waste per capita in 2012 was 588 kg. With zero waste initiatives in

place, it is feasible to reduce the per capita amount to less than 100 kg within ten years. In

Priula, Italy with 554,000 inhabitants and 50 municipalities, they reduced their per capita

rate of residual waste from 321 kg in 2000 to 58 kg in 2012 with an 80% recycling rate and a

80% reduction in its residual waste.4

Recommendation 2: We ask each region to support the development of a zero waste pilot

community to illustrate what can be done to prevent the generation of waste and to

reduce residual waste. See appendix A.

5. Prevention

The regional waste plans call for a 1% per capita reduction of waste generated for the next

five years. We believe that this reduction is too modest. In food waste alone, which

accounts for 33% of the household waste stream, Stop Food Waste calculates that 60% of

this waste is avoidable.5 If we achieve the goal of reducing food waste by 30% by 2025, this

action alone would reduce the amount of waste generated by 10%. Prevention of waste

must be relevant to all streams of waste.

Waste prevention can be achieved through the following actions:

• Increase investment in public awareness, infrastructure development, research and

support for waste prevention actions. Currently in the three regions, around 70% of

the waste funding is allocated towards the ‘lower order’ waste management

activities such as landfill aftercare, street cleaning and litter management and 30% of

the funding goes towards the ‘higher order’ activities such as waste prevention,

reuse, recovery and recycling

• Support businesses in developing new business models that adopt a life-cycle

assessment approach. Provide grants or other financial incentives

• Advance the Green Procurement initiative for all local and national public bodies.

• Encourage a shift in manufacturing and consumption, delinking material

consumption from economic growth. We can learn from policies and programmes

4 http://www.zerowasteeurope.eu/2013/07/europan-champion-districts-of-priula-and-treviso-join-the-zero-

waste-europe-network/ 5 www.stopfoodwaste.ie



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adopted in other countries and build on Ireland’s current waste prevention

initiatives.

• Adopt a series of economic instruments to invoke behavioural change amongst

consumers and producers to manage resources wisely. Such incentives include

o VAT reduction for recycled products,

o Differential taxes between use of primary material and secondary material in

manufacturing –

� There are two ways to differentiate taxes between use of primary

material and secondary material in manufacturing.

• The first option is taxing the use of primary material.

According to European Commission, “Taxes on primary

materials may act to reduce the consumption of materials,

encourage re-use and preparation for re-use, and increase the

use of recycled materials.”6

• The second option is setting a lower VAT rate on secondary

material used in manufacturing.

• Both these options are able to make secondary more

economically attractive and increase their demand. In terms of

acceptability to companies, the second option is more positive

than the first one.

o Impose deposit/refund schemes for take-back programmes (such as a

container deposit/refund schemes which are hugely successful in many US

States, Germany, Scandinavian countries and other countries to capture

plastic, glass, tetra pack and aluminium drinks containers). See Recycling

Section.

o Increase the landfill levy progressively. The Irish landfill levy is one of the

highest in European Union and it is an important factor for internalising

environmental externalities of landfills. In the name of continuous

improvement, the levy should be progressively increased to reflect the

performance that is possible to achieve with all the prevention programmes

and recycling technologies available.

o Impose a levy on WtE plants. As there are at least two MSW incinerators in

project or operational, it is time to implement an incineration tax as well, to

make incineration or WtE less favourable than reuse and recycling. The basic

rate should be the same as the landfill levy with a reduction of tax for energy

efficient facilities (under the WFD), to match with European waste hierarchy.

o Tax use of natural resources rather than labour

o Levy on excess residual household waste -- In order to reduce residual

household waste and promote recycling at the same time, the European

Commission recommended that municipalities introduce a levy on excess

residual household waste (with refunds to those whose residual waste is

6 Bio Intelligence service for European Commission (DG Env) “Use of economic instruments and waste

management performance”, April 2012, p. 12:

http://ec.europa.eu/environment/waste/pdf/final_report_10042012.pdf



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below the average level )7. Indeed, the quantity of residual waste per

inhabitant is a good indicator for the effectiveness of sustainable

consumption and restraining it would help to achieve resource efficiency.

o Extend the tax on plastic bags to disposable products that have reusable

equivalent. Consumers have an important role to play in achieving resource

efficiency. To modify their habits, they need to have a clear price-signal on

what product is more resource efficient and what product is not. The tax on

plastic bags has shown its effectiveness and should be extended to other

disposable products that have reusable equivalent, as disposable tableware,

plastic films, etc (see the Belgium picnic tax).8

Recommendation 3: We propose that the target for waste prevention be increased to 2%

per capita per year and funding for prevention activities, public awareness.

Recommendation 4: We also propose the adoption of the economic instruments detailed

above.

6. Source segregation

As detailed in the proposed waste management plan, most of the households with kerbside

service have at least two bins and a minority with three bins.

There is a trade-off in the methodology of collecting dry recyclables…contamination versus

ease of use. On the one hand, food stuff caked on tins or remnants of fizzy drinks in

collected cans can contaminate paper/card. However, on the other hand, if there are too

many collection streams, it may become confusing and frustrating for the consumer.

Ideally, it would be preferable to collect recyclables in separate streams as the quality of the

material would be much higher and ultimate processing much easier.

According to a June 2009 study conducted by WRAP in the UK, “Choosing the Right

Recycling Collections System,” the greatest benefit for recapturing valuable resources is

achieved through a closed loop recycling “where materials are put back into the same or

equivalent application.” They state that the best method of recovering high quality

recyclable material is through a kerbside sorting system where materials are sorted by the

household for collection. 9

The Department for the Environment, Food and Rural Affairs (DEFRA) in the UK has advised

local authorities that “source separation of materials is the first step to maximising the value

7 Bio Intelligence service for European Commission (DG Env) “Use of economic instruments and waste

management performance”, April 2012, p. 12:

http://ec.europa.eu/environment/waste/pdf/final_report_10042012.pdf 8 http://www.prewaste.eu/index.php?option=com_k2&view=item&id=288:26-ibge-ecotaxation-plastic-

bags&Itemid=94 9 http://www.wrap.org.uk/sites/files/wrap/Choosing%20the%20right%20recycling%20collection%20system.pdf



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of recycling,” and that “the earlier in the collection chain a recyclate is separated the lower

the likely costs and environmental impact of the collection scheme.”10

The benefits of source separating at the kerb are manifold. Such benefits include:

• Less contamination of recyclable material. According to a WRAP study of MRFs in

the UK, US and EU, there was a contamination rate of up to 20 percent.11 Less than

1 percent of source separated recyclate is wasted.

• Increased revenue for sales of the materials.

• Staff collecting separated materials can give immediate feedback to households who

have improperly put out unrecyclable items with a note of what can be accepted.

• Trucks can be retrofitted with extra compartments to collect various recyclable

material streams.

• There is more trust on behalf of households on the collected material being recycled.

Many individuals don’t believe that commingled recyclate is actually being recycled.

In fact, they are right as up to 20% is contaminated and thus wasted.

• Total cost of collection and processing together are lower in source separated

systems than in commingled systems.12

• The trend in recyclates markets is likely to be towards higher quality material.13

Recommendation 5: The Environmental Pillar recommends the adoption of a kerbside

sorted system of collecting recyclable materials to guarantee a higher quality of feedstock.

However, if trucks are not easily retrofitted to add more compartments, we recommend a

2-stream commingled system of dry recyclate over a single stream. Separating paper and

card from metal and plastic containers would yield a higher quality of paper material.

Additionally, all households and food businesses must have an additional bio-waste bin

for separate collection.

As mentioned in the plans, there is an over-capacity of pre-treatment facilities in Ireland and

in the future, there needs to be better coordination between the local authorities, regional

waste authorities and EPA when certifying new facilities. Additionally, we agree with the

plan that additional biowaste treatment facilities are needed, especially with the national

roll-out of the brown bins and the enforcement of the Commercial and Household Food

Waste regulations.

10

DEFRA (2005), “Guidance for Waste Collection Authorities on the Household Waste Recycling Act 2003”,

www.defra.gov.uk/ENVIRONMENT/waste/legislation/hwra/hwra-guidance.pdf 11

Friends of the Earth (UK) Briefing (September 2009), “Recycling collections—source separated or

commingled?”; Dougherty Group LLC for WRAP (2006), “Materials Recovery Facilities,”

www.wrap.org.uk/document.m?id=3528 12

WRAP (2008), “Kerbside recycling: indicative costs and performance.”

www.wrap.org.uk/downloads/Kerbside_collection_report_160608.41243a68.5504.pdf; Friends of the Earth

(UK) Briefing (September 2009), “Recycling collections—source separated or commingled?” 13

Friends of the Earth (UK) Briefing (September 2009), “Recycling collections—source separated or

commingled?”



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We question the need for the Poolbeg WtE plant as well as a further proposed 300,000

tonne WTE facility. Further detailed rationale is contained in the Energy Recovery section

below.

7. Energy Recovery is limited to non-recyclables

Export figures

Ireland exports its waste mainly to Germany, the Netherlands, Denmark, Sweden and the

UK. The estimated cost of this, including all packaging and shipping, has been put at 80-100

euro per tonne by an Irish study14 and 46-174 euro per tonne, for international export, by a

European study15. The planned facility in Dublin is proposing a gate fee in excess of the

lower bound of this range in its optimistic estimations, approximately 110 euro per tonne

and on par with this figure in its most pessimistic projections, at 80 euro per tonne16. Thus

there appears to remain risk of competition from international incinerators in the most

pessimistic of financial projections. This is particularly true at the moment due to the

undersupply of waste in many incinerators across Europe, which has led to very competitive

gate fees in receiving plants, as low as less than 50 euro in countries like Germany and

Denmark, and a lack of taxes on incineration across the EU, currently only six member states

have incineration taxes, and in many cases taxation is as low as 1 or 2 euro per tonne17

Overcapacity

There are currently 406 incinerators operating across Europe. These comprise an estimated

total capacity of 54 million tonnes, as of 2010.18 Many of these plants are already struggling

to reach capacity and thus are relying on a Europe wide export market for waste. Despite

declining waste levels and undersupply of waste to existing plants, there are plans for

continued expansion in the sector, with 48 new plants planned. This would constitute an

14

Dublin waste to energy, waste market assessment, RPS pg.39 2014

15 http://ec.europa.eu/environment/waste/pdf/final_report_10042012.pdf

16

Dublin waste to energy cost benefit analysis PWC pg.13

17

[vii] Incineration overcapacity and waste shipping in Europe, the end of the proximity principle?

GAIA pg 18, 2013

18 Incineration overcapacity and waste shipping in Europe, the end of the proximity principle? GAIA

pg.6, 2013.



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increase in capacity of 13 million tonnes up to 202019 as well as an increase in the capacity

of some existing incinerators, including in Ireland, with a proposed 10% increase in capacity

planned for the Indaver incinerator in Co. Meath, an incinerator with a current capacity of

200,000 tonnes.20

There is currently more incinerator capacity than residual waste in many member states,

and if Ireland is to meet its EU obligations to recycle 50% of its MSW by 2020 and 70% by

2030 as well as provide needed feedstock to WtE facilities, it will be relying on an increase

in waste generation to ensure it can maintain a residual waste stream so as to reach

capacity in its national incinerators. This is especially true if trends continue in Europe, and

gate fees in other countries decrease further. According to a report on the Irish waste

market this growth in waste is expected to be an increase of 1,211,381 tonnes up to

2030.21 Much of this projected increase is attributed to population growth as well as a

stronger economy. However 2012 EPA figures put municipal waste generated at 4.6% less

than the previous year and Irish household waste generation per capita at 344 kg, below the

EU27 average, despite consistent population growth, and improved economic indicators.22

8. Inefficiency

This increased investment in incineration is at odds with the Europe wide commitment to

decreasing waste generation, given its reliance on residual waste streams. According to the

EU Commission’s ‘Roadmap to a Resource Efficient Europe’, key milestones include having

waste generation per capita in absolute decline, as well as energy recovery limited solely to

non-recyclable materials.23Increased investment in incineration, which is reliant on residual

waste streams, undermines the goal of declining waste generation and the scientific

evidence on the energy recovery limitations of solely non-recyclable materials and the

necessity of highly calorific materials for the incineration process is at odds with EU

commitments to limit energy recovery to these materials alone. A scientific study carried

out showed that recycling materials conserves three to four times more energy than

incineration, and that the only waste streams that produced energy at a rate close to

19

Incineration overcapacity and waste shipping in Europe, the end of the proximity principle? GAIA pg.12, 2013. 20

Dublin waste to energy, waste market assessment, RPS, pg.34, 2014.

21 Dublin waste to energy, waste market assessment, RPS, pg.17, 2014.

22 http://www.epa.ie/pubs/reports/waste/stats/EPA_NWR12_Complete_to_web_5Aug14.pdf

23 http://ec.europa.eu/environment/resource_efficiency/pdf/com2011_571.pdf



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recycling were food, wood and yard waste24This leaves investment in a process which is

either diverting recyclable and biodegradable materials from more energy efficient and

environmentally sound recycling practices, contradicting the EU’s own goals in its

framework for resource efficiency in europe, or alternatively in an inefficient process which

recovers little actual energy.

9. Alternatives, job creation and market risks

In Ireland’s ‘Strategy for Renewable Energy 2012-2020’ the government outlined five main

areas of importance for Ireland’s future renewable energy sector. Of these, wind, tidal and

bioenergy were targeted as areas for development and potential economic gains.25The gains

to be made in the bioenergy sector included boosting job creation in rural areas through

bioenergy enterprises and their refit3 scheme for biomass technologies. It is under this

same scheme that the proposed incineration facility in Dublin is to receive subsidies for 57%

of its electricity output, at a guaranteed price 20% over market electricity price of 71.2 euros

per MWh, for the first 14 years of operation.26 An alternative treatment for the biomass

element of municipal waste is anaerobic digestion, which the government outlined in a 2011

report as being an important area of ongoing investment and development. According to

this report investment costs for a 380kw anaerobic digestion plant stand at approximately

1.5 million euro and capital investment is put at 4,000 euro per kilowatt27. The report also

estimated that development in this area could see the creation of nearly 8,000 jobs per

1,000 plants built as well as constitute a boost to the farming sector and rural

development.28

Expansion of the waste to energy sector seems at odds with their previous proposals on

renewable energy given the inefficiency of the technology, the available alternatives, as well

as the risky returns to the project in a competitive EU market. Investment would be better

served developing new energy sectors, given our abundance of natural resources, as

24 http://www.ewp.rpi.edu/hartford/~ernesto/S2014/SHWPCE/Papers/SW-Preprocessing-Separation-

Recycling/Morris1996-Recycling-vs-Incineration-Energy.pdf pg.292

25 [xv] http://www.dcenr.gov.ie/NR/rdonlyres/9472D68A-40F4-41B8-B8FD-

F5F788D4207A/0/RenewableEnergyStrategy2012_2020.pdf pg.9

26 http://www.dcenr.gov.ie/NR/rdonlyres/9472D68A-40F4-41B8-B8FD-

F5F788D4207A/0/RenewableEnergyStrategy2012_2020.pdf

27

The development of anaerobic digestion in Ireland, joint committee on communications, energy and natural

resources, 2011. Pg. 4 28

The development of anaerobic digestion in Ireland, joint committee on communications, energy and natural

resources, 2011. Pg. 9



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outlined in the government’s own energy strategy.29The potential for job creation in the

WtE project is limited, with many of these jobs being temporary, being only available during

the building of the project whereas 19,000 jobs have already been created in the green

sector with a potential for an additional 10,000.30 There is opportunity for sustained job

creation and sector wide development in newer, green technologies as well as in developing

recycling facilities. In many towns and cities across Europe, local authorities have found an

economic opportunity in developing their circular economy, by creating strong recycling

networks and focusing on local production they have boosted their local economies, created

jobs and saved money. An Italian town council saved 2 million euros when they engaged on

a zero waste strategy and others like it have been similarly successful.31

As well as our current WtE capacity of 200,000 tonnes, there are other treatment options

available for municipal waste, among them three cement kiln facilities operating in the

country which accept waste. The total consented capacity of these facilities was 342,875

tonnes in 2012 with 121,214 tonnes actually being recovered in the same year.32According

to a 2012 EPA report there is a national capacity for biological treatment of waste of

550,000 tonnes.33 Given our current export rate of over 800,000 tonnes, if waste projections

are incorrect and recycling efforts improve in line with EU directives, there is a potential for

incineration overcapacity, particularly if waste exports continue as they have been due to

market competition. The UK has a potential overcapacity of 6.9 million tonnes of waste if

current expansion plans go ahead and despite this there has been a growth in the export of

residual waste from the UK to other countries in Europe, one British study estimated an

export market for waste of 2 million tonnes in 2020, despite over capacity risks.34 Other

European countries, such as Belgium and the Netherlands also have strong import and

export markets for their waste. The Netherlands is a prominent exporter of waste despite

running an overcapacity of 600,000 tonnes a year.35 Expanding incinerator capacity in a

country is no guarantee that waste will stay in it. The waste framework directive has opened

up a Europe wide market for waste,36 which waste operators across the continent are taking

advantage of. Incinerators run at extremely high operating costs and on very tight profit

margins, in such a competitive market, there is a real threat that the proposed facility in

Dublin will simply not be able to compete.

29 Dublin waste to energy, waste market assessment RPS pg.26 2014.

30

http://www.dcenr.gov.ie/NR/rdonlyres/9472D68A-40F4-41B8-B8FD-

F5F788D4207A/0/RenewableEnergyStrategy2012_2020.pdf pg 8 31

Zero waste Europe, case study, the story of Capannori, pg.4 32

http://www.epa.ie/pubs/reports/indicators/00061_EPA_SoE_2012.pdf Table 5.1 33

http://www.greeninvestmentbank.com/media/25376/gib-residual-waste-report-july-2014-final.pdf 34

http://www.greeninvestmentbank.com/media/25376/gib-residual-waste-report-july-2014-final.pdf pg 16 35

http://www.iswa.org/uploads/tx_iswaknowledgebase/Berthoud.pdf pg 2 36

1 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and

repealing certain Directives



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10. Environmental and health impacts

According to the Regional Plans, the current amount of waste landfilled in Ireland is in the

order of 1,027,577 tonnes per anum. Given that 20% of waste from incinerators needs to be

disposed of after treatment, this is not the best technology to substantially bring this figure

down, and in line with EU targets. The only municipal waste incinerator operating in the

state currently generates 40,000 tonnes per annum of bottom ash. Of this only 5,000 tonnes

of ferrous metals are extracted and 1,500 tonnes of non-ferrous metals are extracted for

recycling. The rest is used an engineering material on landfills. 11,000 tonnes of boiler and

flue gas treatment residue are exported for underground stowage. This is a substantial

amount of the original 200,000 tonne capacity not diverted from landfill or fully recovered,

not to mention the much more difficult to manage and highly toxic fly ash which remains a

health hazard and air pollutant. The detrimental environmental effects of incineration are

well known, a 2000 public health report outlined the health risks to people living near an

incineration plant and to the plant workers themselves from dioxins and other dangerous

contaminants37 and a 2009 report on a planned incineration facility here in Ireland outlined

a number of public health concerns regarding fine particle emissions, including respiratory

and cardiovascular illness and premature mortality.38

Despite efforts to filter and reduce emissions as much as possible, studies have found that

these ultrafine particles may actually be more dangerous than the larger particles which are

being removed. Excess deaths from particle inhalation in the EU have been put at 370,000 a

year.39 There are further environmental and public health concerns regarding not only the

toxicity of the incineration residue, but the precarious nature of the process itself. One

paper from the University of Cork outlined the potential health and environmental hazards

posed under a scenario where insufficient waste is available to keep the process operating

at maximum levels. The process requires a fine balance of waste, oxygen and heat, and a

constant supply of feedstock. A threat exists if not all dangerous substances are destroyed

during the process or in a situation where incomplete combustion has the potential to

create new, even more dangerous substances such as dioxins and ferans, known

carcinogens.40 There have been calls over recent years from the scientific community here

for more in depth analysis of the potential health risks of these facilities to the local

community, and more worrying still criticism of those that were carried out as inadequate.41

In fact, the initial environmental impact assessment which was carried out, and under which

37

Waste Incineration and Public Health (2000), Committee on Health Effects of Waste Incineration, Board on

Environmental Studies and Toxicology,

Commission on Life Sciences, National Research Council, National Academy Press, pp. 6-7.

38

http://www.durhamenvironmentwatch.org/Incinerator%20Health/CVHRingaskiddyEvidenceFinal1.pdf pg.4 39

http://www.durhamenvironmentwatch.org/Incinerator%20Health/CVHRingaskiddyEvidenceFinal1.pdf pg.4 40

http://www.ucc.ie/en/appsoc/researchconference/conf/cstj/cstjournalvolume32011/robertcorrigan/RobertCorriga

n.pdf pg 106 41

http://fiasco.ie/incinerator/resources/Critique_of_Health_Assessment_in_EIS_-_Dr_Anthony_Staines.pdf



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the license was granted, has come under heavy criticism for failing to adequately assess any

of the potential health implications for local communities.42

Lastly, if Ireland pushes more towards WtE to ‘recover’ its waste, there will be a loss of

confidence with the public. They will question the need to recycle at all since they have the

impression that it will be burned anyway.

Recommendation 6: The Environmental Pillar recommends a change in waste policy to

move away from incineration/waste to energy as a waste treatment technology and to

move towards the adoption of ‘zero waste’ principles.

11. Recycled Waste is used as a reliable source of raw material

Globally electronic waste represents a $130 billion opportunity. Mobile phones contain

more gold than the ore dug out of mines.43 Rare earths are as their name implies rare, and

are only to be found in certain parts of the planet, where their export may be restricted, or

the location is one of continuing wars and civil strife. These rare earths are essential to the

high tech tools we rely on for our clean-tech and other industries.

The collection for the recycling of Waste Electronic and Electrical Equipment (WEEE) is very

important and should be the first priority for WEEE. The government should focus on

methods to increase the repair and reuse of various types of WEEE, including computers,

printers, copying machines, appliances and other types of electronics. This focus will not

only reduce energy and resource usage, but it will also encourage the development of new

businesses and jobs.

Recommendation 7: Develop closed loop policies for all materials streams, with labour

intensive recycling as a priority.

Along with a tax on all one way packaging the government should support the introduction

of a deposit-and-refund scheme for recyclable containers, including glass bottles, plastic

bottles, aluminium cans. Ireland currently only recycles just above 55% of our aluminium

cans, which is one of the most recyclable products. If a deposit/refund scheme were in

place, up to 97% could be recovered (amount recovered in the State of Michigan). Many

drinks containers are lost in the waste stream because they are bought while away from

home. Most individuals do not keep the cans or bottles until they return home or reach a

recycling bank. However, if there were a deposit of around 10 cents on each drinks

container, people would either keep the can or bottle, return it to a local shop or

organisations will collect them for fundraising causes.

42

http://www.ucc.ie/en/appsoc/researchconference/conf/cstj/cstjournalvolume32011/robertcorrigan/RobertCorriga

n.pdf 43

http://www.ellenmacarthurfoundation.org/circular-economy/circular-economy



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Recommendation 8: Introduce deposit-and-refund schemes on all recyclable drinks

containers on a pilot basis to test the validity of extending the scheme nationally. See

Appendix B.

1st July 2010 is the date the Food Waste Regulations (SI 508 of 2009) entered into force in

Ireland. The Regulations require major producers of food waste to source segregate food

waste, ensure that it is not mixed with other waste and make it available for a brown bin

collection service where it is recycled in a food waste recycling plant (e.g. composting plant

or anaerobic digestor). Alternatively, waste producers can bring the food waste directly to a

food waste recycling plant; or the food waste can be treated by composting it on the

premises where it is generated. Similar regulations were adopted in 2012 for household

food waste separation and collection.

It is estimated that there are at least 250,000 tonnes of food waste disposed of by

commercial businesses in Ireland each year44, as well as large volumes of food waste

generated by individuals throughout the country. While not all of this is reusable, it is

estimated that at least 60% of food waste is avoidable.45

Recommendation 9: Prioritise the implementation of the Food waste regulations and to

investigate the use of surplus edible foods currently discarded as waste.

Recommendation 10: Promote the development of anaerobic digestion of biowaste

streams at community level to deliver combined heat and power and to recycle nutrients

to the soils from whence they came.

Hazardous waste is safely managed and generation is reduced

The waste plan calls for a 50,000 tonne WtE incinerator to burn hazardous waste. The

Environmental Pillar recommends that instead of looking at hazardous waste to be burned

investigate other types of management techniques. Firstly, we call on the regions to

organise more household hazardous waste collections, new extended producer

responsibility initiatives for hazardous waste streams and the establishment of a more

innovative and effective symbiosis programme.

12. Industrial symbiosis

Industrial symbiosis is simply the idea that waste and by-products of one company can

become the resources of another, thus reducing the use of raw materials. It involves three

key components, namely, the exchange of by-product resources, utility and infrastructure

sharing, and joint provision of services.46 It has become an integral part of the circular

economy goals of waste reduction and decoupling resource use from economic growth.

Through coming together to create an integrated network of shared resources, by-products

44

National Waste Database 2011 45

http://www.wrap.org.uk/content/facts-and-figures 46

Uncovering industrial symbiosis, Chertow, Marian R. 2007, pg. 12



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and utilities, companies have reaped many benefits, they have cut costs, created and

safeguarded jobs as well as improved their environmental performance. These networks

have become so successful that there are now widespread governmental efforts to fund and

support these processes.

The United Kingdom in particular is leading the way in supporting such networks, through

their ‘National Industrial Symbiosis Programme’. The programme is a voluntary instrument

which assists businesses in redirecting their waste from landfill by helping them find

businesses to connect with, allowing them to exchange their waste as a resource, creating

substantial savings and realizing significant environmental gains. The programme began as a

private collaborative effort between businesses and evolved into a nationwide programme

funded by the business resource efficiency and waste programme.47The programme now

comprises of over 15,000 businesses and has seen significant economic gains for the regions

in which it has been implemented. Each region in the UK in which the programme is active

has seen gains of over 60 million pounds, over a five year period, as well as seeing 10,000

tonnes of waste diverted from landfill, the creation of 100 new jobs and substantial

reduction in water and energy use.48

Nationwide the benefits have been significant, saving the companies involved 1 billion

pounds and generating a further 1 billion pounds in additional sales, it is also credited with

creating or safeguarding 10,000 jobs across the UK.49 The environmental impacts have been

just as impressive, the programme has allowed 47 million tonnes of waste to be recovered

or reused as of 2013, industrial carbon emissions have been reduced by 39 million tonnes,

1.8 million tonnes of hazardous waste have been reused, there has been a 73 million tonne

industrial water savings made, as well as 60 million tonnes of virgin material.50 Northern

Ireland has seen similar success figures from its participation in industrial symbiosis

programmes, allowing businesses to cut costs by 5.5 million pounds, generate 12 million

pounds in new sales as well as create or safeguard 71 jobs. Environmentally they have been

able to divert 139,000 tonnes of industrial waste from landfill, reduce carbon emission by

247,000 tonnes and save 130,000 tonnes of virgin material.51

Other European countries such as Denmark and Switzerland have also seen success with

similar networks, and the EU, impressed with the success of these enterprises in other

countries, has begun supporting fledgling projects in countries such as Romania and

Hungary through its Life+ programme. These nascent projects are already reaping the

economic and environmental benefits. In Romania, the 178 companies involved have

already reused half a million tonnes of waste and saved 135,000 tonnes of CO2. Through the

reuse of wood and sawdust 2,500 hectares of forest have been saved.52

47

Waste management policies for industrial symbiosis development, case studies in Europe, Journal of cleaner

production, 2010, pg. 818 48

The Industrial Symbiosis Research Symposium at Yale:Advancing the Study of Industry and Environment,

2004,pg.11 49

http://www.international-synergies.com/projects/national-industrial-symbiosis-programme-nisp 50

http://www.international-synergies.com/projects/national-industrial-symbiosis-programme-nisp 51

http://www.international-synergies.com/projects/maximising-efficiencies-energy-waste-industrial-symbiosis-

service-for-invest-northern-ireland 52

European Commission, Eco-innovation Action Plan



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These industrial symbiosis networks have been recognized on a supranational level as

having the potential for enormous economic as well as environmental benefits. The national

industrial symbiosis programme in the UK in particular has been pinpointed by the European

Commission as providing the “highest economic benefit to the companies involved”53 and

suggested that a Europe-wide network would prove even more successful, recommending

that similar programmes be rolled out in all 28 member states.54 In 2010 the organization

for economic-cooperative development (OECD) recognized industrial symbiosis as “vital for

future green growth.55

Governments can help foster such important networks by creating a policy landscape

conducive to environmental progress. In the United Kingdom, for example, the government

introduced a mix of economic, regulatory and voluntary instruments which have helped

shape the policy context for industrial symbiosis development. As well as the national

industrial symbiosis programme, the earlier landfill tax and waste protocol project helped

foster the development and growth of the networks.56 In Portugal mandatory electronic

information reporting on waste, landfill and incineration taxes as well as a voluntary

instrument, the ‘organized waste market’, which facilities transactions of waste materials

and promotes recycling, have helped created a context that supports the development of

industrial symbiosis networks in the country.57On a subnational level, Geneva, Switzerland

introduced the concept of industrial ecology into law, with article 12, which stipulates that

the state “facilitate the possible synergies between economic activities in order to maximise

their environmental impact” and also established an advisory board for industrial symbiosis

implementation.58

By using economic and legislative instruments as a disincentive to overuse resources and by

creating economic advantages to recycling and reuse governments can help to foster a

landscape that allows for the development of these symbiotic networks. Through direct

national and sub-national funding these networks can be developed and expanded, bringing

huge economic and environmental benefits to both the companies involved and also to the

country as a whole. Countries within the EU should see industrial symbiosis as an integral

part of the EU’s plan for a circular economy, allowing businesses to cut costs and improve

sales, decouple resource use from economic growth, and provide essential environmental

progress at low cost. Industrial symbiosis is being seen globally as a vital component of a

new economic paradigm and countries should take advantage of the potential gains it can

bring through the use of economic instruments that incentivise environmentally progressive

53

http://pprc.org/wp-content/uploads/2012/05/ISL_report.pdf pg.2 54

http://pprc.org/wp-content/uploads/2012/05/ISL_report.pdf pg.2 55

http://pprc.org/wp-content/uploads/2012/05/ISL_report.pdf pg. 2 56


production, 2010, pg. 818

57



58





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business practices and by creating a policy landscape that fosters these innovative

programmes.

Recommendation 11: We propose the establishment of regional and/or national

symbiosis programmes to foster and assist in the development of industrial symbiosis

networks.

13. Monitoring and Enforcement

The plans outline the current funding mechanism for monitoring and enforcing waste

permits and actions. Currently, local authority enforcement teams are granted money from

the Department of Environment, Community and Local Government from the

Environmental Fund through to the end of 2014. How will permits and actions be

monitored and enforced from 2015 and onwards? The number of inspections by local

authorities of the packaging waste regulations has reduced significantly between 2007 and

2011, from 3,104 to 1,187 inspections. From 1997 until 2010, there were 50 prosecutions,

mostly before 1997 and 64% by the Dublin City Council.

In 2012, the Eastern Midlands Region conducted nearly 50,000 inspections, many in relation

to the enforcement of the food waste regulations with 157 prosecutions.

Unlike all other EU member states, Ireland’s waste collection and treatment is done through

the private sector. There must be adequate and effective monitoring and enforcement of

their activities to ensure that the waste streams are responsibly managed and treated and

that there is not a race to the bottom in terms of waste management as waste companies

vie for both residential and commercial business.

Recommendation 12: There must be adequate and sufficient funding for local and

regional authorities to monitor and enforce the proper management and treatment of

waste to ensure that the waste hierarchy is properly enshrined in the ultimate use of

valuable waste resources.

14. Food Waste is reduced

EPA’s Office of Waste Prevention has supported Stop Food Waste programme and its

various initiatives listed in the plans. The Pillar supports the work being done by this

programme and urges an increase in funding to continue its work with households,

communities, food businesses and the hospitality sector. The reduction in food waste will

only occur with a significant change in individual and corporate behaviour which requires a

considerable increase in funding.

15. Biowaste treatment

As detailed earlier in this submission, an Oireachtas committee in 2011 recommended the

investment in anaerobic digestion as an efficient treatment technology for food waste (one



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million tonnes) as well as other biowaste such as slurry (40 million tonnes per annum59,

which does not reflect the proposed increase in the national herd) and industrial, sewage

and water treatment sludge (564,642 tonnes per annum) to generate renewable power and

heat. Breakdown of the 2012 sludges per region are below, gleaned from the regional

waste plans:

Region EMWR SWR CURWR

Industrial Sludges 2,648 tonnes 9,685 tonnes 454 tonnes

Sewerage Sludges 227,998 tonnes 144,525 tonnes 99,794 tonnes

Water Treatment

Sludges

43,933 tonnes 7,255 tonnes 28,350 tonnes

Total Amount Sludges

2012

274,579 tonnes 161,465 tonnes 128,598 tonnes

Situation in Ireland:

• We have 40 million tonnes of animal manure annually. This slurry is being

overspread onto farms and causing damage to local waters.

• We have 1 million tonnes of food waste annually

• Composting or digesting this improves its usability by stabilising and locking up

nutrients for slower release into the soil.

• A 200 head dairy cow farm could produce enough slurry to generate 30-75 kW of

power with as much heating for space and hot water or greenhouse heating. (could

be used for district heating)

A SEAI funded case study in 2010 is below:

David McDonnell Farms Biogas Ltd, Co. Limerick60

This AD plant operates 8,000 hours per year, which generates in the region of 2,000,000

kWh electricity and 2,100,000 kWh heat. Mr. McDonnell receive 15 c/kWh for the

electricity exported to the grid. The heat generated is used in the plant itself, for the

pasteurisation and on the farm for heating the poultry sheds to replace fossil fuels. He

digests 10,760 tonnes of biowaste feedstock which includes cattle slurry, food waste,

poultry litter, dairy sludge and glycerine.

Output:

Availability CHP unit: ~91%; 8,000 full load hours/a

Biogas production: ~950,000 m3/a (55% CH4 content, 20 MJ/m3)

59

http://www.dcenr.gov.ie/NR/rdonlyres/287C17F6-13D2-48B9-882C-2060512A573E/0/EPAappendix.pdf

Stapelton, L., Lehane, M. and Toner, P. 2000. Ireland’s environment – a millenium report. Environmental

Protection Agency, Johnstown Castle Estate, Co. Wexford , Ireland, 270 pp.

60

http://www.seai.ie/Publications/Renewables_Publications_/Bioenergy/Anaerobic_Digestion-

Shanagolden_Case_Study_2010.pdf



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Electricity production: ~2,000,000 kWh/a, mostly exported to the national grid

Heat production: ~2,100,000 kWh/a, heat exported for heating the plant, for pasteurisation

and for heating the poultry sheds

Primary energy savings: ~1,200 MWh/a

CO2 savings: ~1,500 t CO2/a

Total capital cost: ~ €1.5m

SEAI CHP grant: €108.000

Payback time: approx. 10 years

REFIT: 15 ct/kWh exported electricity indexed linked for 15 year

An average Irish Household uses 5,300 kWh annually. This farm produces enough electricity

to serve nearly 400 households annually. If Ireland produces over 41.5 million of biowaste

each year (food waste, sludges and slurry), this could provide enough electricity to power

over 1.5 million households and provide heat to pump into district heating systems.

16. AD plants internationally

Germany has 7,000+ on-farm biogas facilities producing 2-3 times the energy of the

country’s nuclear power plants. Unfortunately, these are currently being fed maize.

However, with the constant supply of sludges and slurry, Ireland has a ready renewable

feedstock for anaerobic digestion, although the development of this industry to treat

biowaste has been slow in the uptake due to the low refit rates in Ireland (15c/kWh in

Ireland vs. 28c/kWh in UK, Italy, Germany, France and Hungary).

Recommendation 13: Increase the REFIT rate for anaerobic digestion to encourage the

development of this industry and provide government assistance in terms of grants, loans

or guarantees.

17. Reviews of existing product and waste legislation

Currently, there are 6 streams of waste with extended producer responsibility initiatives

(PRI) schemes: packaging waste, WEEE, End of Life Vehicles, batteries and accumulators,

used tyres, farm plastics and construction and demolition waste. However, as the report

states, this scheme should be extended to paints, medicines, bulky wastes, chemicals and

oils, newspapers and magazines.

Each waste region spends a significant amount of its budget, sometimes as much as 45% (in

the EMWR) on litter clean up and street cleanings, which includes the servicing of street

bins. Much of the waste is packaging although the cost of managing this waste is born by

the municipalities and the taxpayers, rather than the producers. The regional waste plans

state that €103.34 million was spent on litter and street sweeping as well as the

management of street bins and that the counties were facing a financial shortfall in

providing these services in the region of €93.68 million.



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Region EMWR (€M)

(%budget)

SWR (€M)

(%budget)

CURWR (€M)

(%budget)

Litter 11.69 (38%) 6.42 (8%) 4.28 (16%)

Street Cleaning 60.71 (7%) 16.77 (21%) 3.47 (13%)

Total Expenditure 72.4 (45%) 23 (29%) 7.74 (29%)

Total Income 2.1 `1.5 1.93

Total Shortfall 70 21.5 2.18

Recommendation 14: We propose that the regional authorities investigate possible

financing mechanisms through the packaging PRI to fund the management of packaging

waste found in street cleanings, litter collections and street bins. Such funding could also

be used to provide increased number of separate recycling bins on streets.

18. Increase public information campaigns to stimulate a change in

behaviour

The only way to prevent the creation of waste and to recycle properly is to change the

behaviour of businesses and individuals. The plans earmark €0.15 c/inhabitant to spend on

local prevention projects, which amounts to around €690,000 per annum for local projects.

This amount must be increased significantly as research indicates that a bottom up

approach to changing behaviour is much more effective than a top down advertising

campaign or policy initiatives alone. They must go hand in hand. For instance, Scotland has

adopted a Zero Waste regime and has set up a £10 million zero waste fund to assist local

communities in their zero waste programmes.61

While the development of responsible waste management policy and actions are essential,

the government must ensure the buy-in of local government, community groups, businesses

and individuals. Behavioural change does not happen overnight or through education alone

or huge advertising campaigns such as the Race Against Waste or the Power of One. Change

will happen by engaging with communities and individuals and motivating them to change

their behaviour by changing the social norms.62 A study demonstrated that if individuals

believed that most people engage in a certain behaviour, they would as well. This survey

showed that there was a 36% increase in the number of people reusing their hotel towels

when they read a card in the hotel room that said that most people reuse their towels.63

The desired behaviour must have relevance to the individual’s value system because this

way the behaviour will be sustained over time. Purely monetary incentives will change

behaviour until that incentive is removed.

61

http://www.zerowastescotland.org.uk/category/what-we-offer/funding 62

http://www.theguardian.com/sustainable-business/communicating-sustainability-behaviour-change-public-

health 63

http://www.theguardian.com/sustainable-business/behavioural-insights/behaviour-change-sustainability-

debate



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Education and door to door assistance must also be encouraged and resourced. REPAK

conducted research into the recycling habits of households and found that while most of us

(98%) are recycling, 7 out of 10 of us are using the wrong bin.64 This is a huge concern as

improper waste management and recycling habits will contaminate other material in the

same collection vessel, thus directing such material out of the recycling loop and into energy

recovery, a lower waste management technology.

There is a huge field of research and ongoing work on how to change individual behaviour.

It is a huge challenge, but one thing is certain, change will not happen over-night and

resources must be invested into this field and into local communities to facilitate their work.

Recommendation 15: We encourage the regions to increase the amount of money

available for local waste prevention programmes, similar to that adopted by Zero Waste

Scotland. We also advocate for a more bottom-up public awareness/community

involvement to assist in behavioural change in how we manage our waste.

64

http://www.businessandleadership.com/sustainability/item/47957-ireland-moves-up-from-fourt



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Appendix A

ZERO WASTE PROPOSAL

Towns, villages and cities which have implemented zero waste strategies have enjoyed

significant fiscal as well environmental advantages. The plans focus on proper source

separation, household collection techniques, recycling, composting of organic waste and

reuse. This can be achieved through changing attitudes to waste through community wide

education, as well as changing consumption habits. Ultimately the plan focuses on reduction

of waste, with as little residual waste as possible, eliminating the need for environmentally

harmful and costly disposal techniques such as landfilling and incineration. This will

incorporate a focus on community wide re-use schemes, and research on eco-design and

manufacturing. Such an approach would provide more green jobs in recycling collection and

processing industries. Increasing the amount of quality recyclates would provide consistent

supply of feedstock for businesses wishing to develop recycling technology. Additionally, a

change in individual and corporate behaviour would advance the repair and reuse industry

as well as promote industrial symbiosis relationships.

San Francisco, which has 850,000 inhabitants, planned to build an incinerator in 1985, but it

was never built. Instead, they adopted a ‘zero waste’ approach in 2002 and by 2012, it was

able to divert 80% of its waste from landfill. It did this through the complete buy-in from

government officials and the public. It organised compost collections, passed numerous

ordinances to recycle 65% of C&D waste, ban polystyrene food packs in favour of

compostable containers, adopt green policies at all public offices, reduce waste at food

service businesses, impose mandatory recycling and composting, charge a fee on all plastic

bags and ban the selling and use of plastic water bottles in public spaces.

Recently, Slovenia’s capital, Ljubljana has adopted zero waste. “Ljubljana is already the EU

capital with best performance regarding waste separation and waste avoidance; it

separately collects 60 % of municipal waste and generates less than 150kg of residual waste

–what is not recycled or composted- per person yearly. Until 2025 they commit to increase

separate collection to 78 % and decrease the amount of residual waste to 60 kg per person

per year. With this commitment for zero waste, Ljubljana officially rules out building any

incinerator in order to have the flexibility to continue reducing the non-recyclable waste and

push for prevention and recycling (emphasis added).65

If Ireland were to adopt a zero waste paradigm, the waste scenario predicting the amount of

waste to be managed in the future would change significantly. Assuming residual waste of

1,523,577 tonne (2012 figure), an 80% reduction would result in 304,715 tonnes of residual

waste in 2022 or 67 kg per capita. This calculation assumes a stable population. Like many

zero waste communities, an 80% recycling rate is readily achievable given the development

of necessary infrastructure. Ireland generated 2,154,029 tonnes of municipal waste in 2012.

If we were able to recycle 80%, the resulting residual waste would be 538,507 tonnes or 118

kg per capita of residual waste. Given both factors together, a per capita residual waste

amount by 2022 could be between 67 – 118 kg annually. These calculations illustrate that

further thermal treatment in Ireland is not needed.

65

http://www.zerowasteeurope.eu/2014/09/ljubljana-first-eu-capital-to-adopt-a-zero-waste-strategy/



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Financial impact of zero waste strategy

• Schemes in other towns have become self-funding

• Savings are borne from the elimination of expensive landfilling fees as well as

earnings from the sale of recycling material

• These savings can then be reinvested into the scheme ultimately saving households

money on tariffs

• Boost to employment through new zero-waste sectors

• Waste service tax, such as pay-as-you-throw, and money made from recyclables

have also helped to make other schemes self-funding

Initial steps to adopting zero waste:

• Setting goals and targets for regions/towns

• Engaging with town councils and local authorities to encourage them to sign up for

zero waste plans whereby these targets would be met

• Educating the public and getting local groups/businesses/schools/households on

board for a zero waste plan

• Town meetings/school assemblies to instil the importance of zero waste compliance

• Literature released detailing how households can comply and what they can do to

help

Steps to implement plan:

• Door to door collection was paramount in other successful schemes

• Separate waste bins sent to each household

• kerbside collection for source separated materials…the earlier the material is

separated, the higher the quality that is achieved

• Compliance with source separation helped through pay-as-you throw schemes which

uses microchips in stickers on residual waste bags which are read by a reader in the

collection vehicle

• Brown bins sent to each house with kerbside collection of organic waste streams, for

diversion of organic waste streams

• Home composting encouraged with education regarding composting techniques

• Composting kits sent to homes

• Home composting has been encouraged in other towns through an incentive

whereby homes that compost get a reduced waste collection tariff.

• Public canteens supplied with composting machines

• ‘Recycle as you go’ public recycling bins, to increase recycling and also reduce street

litter, this was introduced successfully in Scotland

• Short-supply chain scheme initiated in Italy, for example, with local farming co-ops

where milk bottles can be refilled



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• Tax incentives for shops which sell supplies loosely or with minimal packaging

• Textile collection through social enterprises

• Subsidized reusable nappy scheme

• No more plastic cutlery in public canteens/schools etc

• Other collection schemes such as door to door collection of household hazardous

waste, for example twice a year has been a sufficient level for other areas.

Ultimate focus on waste reduction

• Ultimate focus on eco-design

• Opening of research centres to look at ways to reduce packaging waste

• Pinpointing problem areas regarding unrecyclables specific to certain regions, e.g. in

Italian towns it was noticed that there was a problem with unrecyclable coffee filters

which was a focus of the research centre’s consultation about changes in design and

materials.

• Consulting with manufacturers regarding redesign of unrecyclable products

• Opening of re-use centres to make reuse easier for the community

• Community reuse and recycle events

• Workshops teaching upcycling skills

Success figures from other pilot schemes

• The use of pay-as-you throw schemes increased source separation in Italy by 90%

• The overall volume of waste in the Italian zero-waste town of Capannori dropped by

39% per capita over a 9 year period.

• Residual waste per capita was down 57%

• In the Spanish zero waste town of Argentona a pay-as-you throw system has

decreased residual waste in the collection are by 60%

• In Spain the introduction of brown bins meant just a 2% contamination figure for

organic waste streams in 2009.

• In a Slovenian zero waste town, Vrhnika, which implemented similar schemes,

residual waste per capita is down to 87kg per person with a target of overall waste

per capita of 300kg by 2021

• The Capannori town council saved 2 million euros in 2007, which allowed them to

reduce waste tariffs for households by 20%



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Appendix B

Proposal for a Pilot Deposit Refund Scheme (DRS) in Ireland

Introduction

In the 1950s and 60s, single-use beverage containers began replacing refillable bottles at an

accelerated rate and the use of one-way beverage containers soared. According to the

National Waste Report 2011, by the EPA, only 40% of the municipal waste generated in

Ireland in 2011 was recycled. Regarding packaging waste, only 47.5% of plastics, 38% of

aluminium and around 81% of glass packaging were recycled, the rest ended up in landfill,

or littering streets and the environment.

We send more waste to the landfill than any other nation in the EU 15 and our container

recycling rates are half the rates of our neighbours with deposit and refund systems.

Waste is a significant issue that Ireland cannot ignore. It is costly in many ways, including,

among others, the price of sending the waste to landfill, the damage litter does to Ireland’s

tourism industry, and the cost of producing and importing new materials. Furthermore, if

we continue our current disposal rates, 16 of the 29 available landfills will reach capacity

within the next three years.

Many counties within Ireland have kerbside collections for metal, paper and plastics and

there are also amenity centres and bottle banks (the number of which has reduced by 67



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since its high in of 1989 bottle banks in 2008). However, according to the US Container

Recycling Institute’s report in 2012, kerbside programmes at best recover 40-45% recycling

rate for all beverage containers as 50-70% drinks containers are consumed at home while

30-50% are consumed away from home.66 It is difficult to capture drinks containers that are

consumed ‘on the go’ or by tourists. A container deposit/refund scheme will help retrieve

these single-use containers.

Container Deposit Refund Scheme (DRS)

In Countries where a deposit system has been implemented results have been always

positive. That is the case of the Netherlands, where the government charges a 25c deposit

on all PET bottles which has resulted in a 95% return. In Sweden, they have an 84% return

for their PET bottles and Finland boasts a 92% return for PET bottles as a result of their

deposit/refund system.67

A 2011 Michigan Department of Treasury study found the enactment of a 10 cent deposit

on plastic bottles in Michigan, which began in 1976, has created a 95.9 percent bottle return

rate – the highest in the nation.68 This is applicable to all the states in US where a deposit

system has been implemented, As shown in Figure 1, recycling rates for traditional beverage

container types were more than twice as high in deposit states in 2010 compared to non-

deposit states. PET has a lower recycling rate than aluminium and glass in deposit states

because only three states include most PET beverages in their deposit laws (California,

Hawaii and Maine).

66

http://www.container-recycling.org/index.php/component/content/article/91-outsidenews/354-container-

recycling-institute-releases-special-2013-vermont-bottle-bill-report- 67

http://www.bottlebill.org/legislation/world.htm 68

http://www.cm-life.com/2013/11/04/advocates-fight-to-reform-michigan-can-deposit-laws/



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When we compare the different collection systems, we can see that with a single stream

collection system (kerbside system in which all waste, including recyclable and non-

recyclable material, goes into the same container) only 40% of glass is recycled into

containers and fibreglass; forty percent of glass winds up in landfills, while 20% is small

broken glass ("glass fines") used for low-end applications. In dual-stream systems (in which

recyclable waste is separated from residual waste, such as in the current Irish scheme) 90%

of glass is recycled into containers and fibreglass, with 10% glass fines used for low-end

applications, and nearly nothing sent to landfill. In container-deposit systems, colour-sorted

material results in 98% being recycled and only 2% marketed as glass fines.69

69

(http://www.bottlebill.org/about/benefits/quality.htm



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In the US, access to kerbside recycling has been rising for years, nevertheless, it has not

meant an increase in the beverage container recycling rate. 30-50% of beverages are

consumed away-from-home, at bars, restaurants, offices, parks, educational institutions and

on-the-go. Furthermore, kerbside recycling often is not provided to multi-family residences.

At best, kerbside recycling can deliver a 40-45% recycling rate for beverage containers, as

experienced in the Provinces of Ontario and Quebec, Canada.70

Independent research from the Congressional Research Service (CRS) avers that both

deposit return schemes and kerbside recycling programmes are necessary to achieve high

recycling rates and that having both programmes results in less cost for kerbside recycling.

Specifically,

“Both systems can serve as elements of comprehensive recycling programs. Neither

constitutes a comprehensive program by itself. Neither excludes the use of the other.”

“Deposit systems skim potential sources of revenue

from kerbside programs, but they also reduce the

operating costs of kerbside programs. Local

governments would appear to achieve greater

diversion of solid waste from disposal at a lower cost

per ton if both a bottle bill and a kerbside collection

program were in place.”71

70

http://www.bottlebill.org/assets/pdfs/Curbside%20vs%20Beverage%20Fact%20Sheet.pdf 71

http://www.bottlebill.org/assets/pdfs/Curbside%20vs%20Beverage%20Fact%20Sheet.pdf



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Figure 6 shows that aluminium cans, PET plastics and glass bottles are the most sold

container materials. However, the trend presented shows that plastic containers production

is rapidly increasing while glass and aluminium containers are decreasing. This illustrates

that there is a need for an efficient plastic containers waste management system to adapt to

oncoming market circumstances.

The table above provides more solid proof of the effectiveness of the deposit system; in it

we can see how the recycling rate for carbonated and non-carbonated beverage containers

in the States where deposit system in not implemented is identical.72 However, in States

where a deposit system only applies to carbonated drinks, the collection rate for such

containers is significantly higher than non-carbonated containers where no deposit is in

place.

The effectiveness of these schemes is also appreciable along the shoreline, where littering is

significantly reduced in places with a DRS. According to annual Coastwatch Survey results,

drinks container litter is the most widespread and frequent shore litter in Ireland.73 Apart

from many environmental impacts, it is bad for Irish tourism and green image that the

country wants to convey. In a country with a low population density and long coastline,

waste prevention incentives are needed. With more than 7000 km of seashore, coastal

tourism is likely to grow, so drinks container litter is likely to rise. Once again, the table

below shows that the most common container materials are plastic, aluminium and glass.

72

http://www.container-recycling.org/images/stories/PDF/BottledUp-BCR2000-2010.pdf 73

http://coastwatch.org/Coastwatch.org/Survey.html



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Resource Efficiency and EU Waste Management Priorities

Failure to capture these single-use containers spoils the natural and built environment as

well as wastes valuable resources. One of the EU’s priorities for the foreseeable future is

resource efficiency to capture valuable resources through effective governmental policies

and innovative business practices. The Deposit and Refund System is a proven economic

tool to recover valuable resources.

The Deposit and Refund System (DRS) places a monetary value on beverage containers in

order to encourage users to return them, thus increasing the recovery rate. The

implementation of a DRS would go a long way in meeting the new standards proposed by

the European Environmental Bureau (EEB) for the EC consultation on the Review of the

European Waste

Management Targets. The EEB suggests the following targets:

• Paper and Cardboard: >80 %

• Glass >90 %

• Metals >90 %

• Plastic: >80 %

• Wood: >70 %

• All Packaging >80 %

• Polystyrene and similar type of protective material (if not considered plastic) >60%

EEB suggests the following as implementation dates: as soon as posible for glass, metals and

paper, and 2025 for plastic, wood, all packaging and others. If we compare Ireland’s 2011

recycling data with the EEB’s 2020 proposed targets, we get the following outcome:



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Material 2011 rates 2020/2025 targets

Paper and Cardboards 91.5% 80%

Glass 81.2% 90%

Plastics 47.5% 80%

Metal (Ferrous) 74.0% 90%

Metal (Aluminium) 38.8% 90%

Wood 92.8% 70%

All Packing 70.9% 80%

In this table we can see how only paper and cardboards and wood containers are already

meeting the recycling target proposed by the EEB. Note that plastic and aluminium

containers are furthest away from these proposed targets. Our proposed DRS pilot will

allow Ireland to meet future recycling targets.

Proposed DRS Pilot Programme in Ireland

This report will analyze the DRS pilot programmes recently implemented in Cadaques

(Spain) and eight different places across Scotland to illustrate the benefits of developing a

similar programme in Ireland, as well as propose a DRS pilot that could work in Ireland.

The Spanish pilot programme is located in the Catalonian town of Cadaques, geographically

isolated and with a small population which made the pilot suitable. It was run by Retorna, a

non-profit association grouping NGOs, recyclers, trade unions and users. Its aims were to

show the viability of the DRS, to analyze the environmental and economic impacts, to be an

example for politicians, business, retailers and population and to evaluate the return rate.

In February 2013, Zero Waste Scotland launched eight Deposit and Return pilot programmes

with the help of the Scottish Government’s Environment Secretary. They spent £900,000 on

its implementation. The goal of the programme was to evaluate the public acceptance, the

volume and quality of material captured, whether the material has been diverted from

kerbside collections or landfill, the impact on litter and litter management, increased

footfall, visitors, use of facilities, visitor spend, and the impact on greenhouse gas emissions.

Results from these separate pilots are expected to be released in March 2014.

Technical development

DRS process



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In the proposed DRS pilot, each purchaser would be charged a deposit on every beverage

container included. To be reimbursed, the user must return the empty container to any of

the retailers participating in the pilot. Retailers are responsible for returning the deposit and

storing the empty containers. When retailers send the empty containers back to the system

operator, they get the corresponding amount of money plus a compensation for the

management. After this, the system operator sells the high quality raw materials to the

recyclers. The system is financed through this money and the non-reclaimed deposits. The

Deposit and Refund Systems will co-habit with the current kerbside system.

Consumers return

empty containers

Retailers deliver

containers to

system operator

Retailers buy

beverages from

bottlers

Consumers buy

beverages

SYSTEM OPERATOR

BOTTLERS

BUSINESS (Supermarkets/Retailers)

COMSUMERS

Business pays price of

the beverage plus a 25

cent deposit per unit to

the bottlers

Bottlers deliver to system

operator all the deposits

Consumers pay the

product price plus

deposit

Business refunds

deposit to consumer

when empty containers

are returned

System operator returns

deposits paid by business

plus a management fee.

*Non-returned deposits

help finance the system

Materials and money flow inside the DRS

Source: Report on the temporal implementation of a DRS in

Cadaqués, RETORNA



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Location

In the Spanish scheme, Cadaques was chosen because of its isolated position. It is a small

town located on a peninsula, only reached by a small mountain road. This is an advantage in

order to prevent people from neighbouring towns from bringing their containers to the pilot

project places, since retailers accepted all labelled and unlabeled containers. Its small

population, about 3,000 inhabitants, made it easily workable, and its reputation for tourism

and a culture gave it a bigger public participation in the project. Lastly, the low cost of the

project attracted the local Mayor’s support, which was a key factor for its viability.

In the Scottish case many different locations where chosen including shops, universities,

schools and a festival, which created closed environments to develop the programme.

Setting the pilot in a campus or a festival provides a micro economy that can work as micro

model for a national system. The rates of return for participating containers and non-

participating containers were easily measured (i.e. diverted from other systems). Also,

because of the limited basis, these pilots provided the opportunity to measure behavioural

change.

In Ireland, the location of the project should be either an isolated place such as an island or

mountain town, or a closed-system economy such a University or festival, with a workable

dimension (around 3000 inhabitants), and where the project could count on political

support.

Duration

The Spanish pilot lasted two and a half months, from 15th April to the 30th June. During the

pilot, the recovery rates increased each week with more and more of the residents

returning their single-use containers. During the last week, the pilot had not reached the

maximum return rate because the trend was still growing. In fact, the introduction of a

deposit system has a growth curve that does not stabilize until after at least one year. The

Scottish pilot programme lasted from February until September 2013.

Deposit amount

In the Cadaques pilot there was a 5 cent deposit of which the retailers received 3 cent

compensation per container returned. In the Scottish programs the deposits ranged from 3

to 10 pence, the type of refund varied from cash money to discount vouchers, charitable

donation or even a raffle ticket.

The graphic below shows that the bigger the deposit is the bigger the recovery rate.

International experience has determined that the deposit must be big enough to encourage

returns while small enough to discourage massive fraud (i.e. people bringing containers

from outside and getting the refund without having paid the deposit). According to a

research carried out by Eunomia for Retorna, a five cents deposit would be enough to

ensure a recovery rate of 70 to 90% of the containers.



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Returns rate depending on the deposit amount

Source: Eunomia 2012

Collecting system

In the Spanish pilot, shops and supermarkets owners chose how to manage returned

containers. Once the decision to implement a DRS system is made, the choice between the

installation of a return vending machine (RVM) (loaned by Tomra) and taking containers

manually would depend on the kind of retailer and the volume of returned containers. In

general, supermarkets prefer to install a RVM in order to reduce both the time that

operators have to dedicate to this task and the space taken by containers. On the other

hand, small shops, where selling volume is lower, collections are often done manually. With

RVMs, the machine indentifies containers based on their weight, material and bar codes,

checks that it is part of the DRS program, and prints out a ticket exchangeable for cash at

the till. Every day data is downloaded onto the system operator server, which checks how

many containers have been returned. Every month the deposit amount is given back to

supermarkets, plus a supplement of 3 cents per container returned as compensation.

In the case of manual collection, shop assistants visually identify the containers and return

the deposit amount. Returned containers are placed in a big bag that, once filled, is given to

the central system collection service. To ensure the reliability of the data taken, the shop

assistants seal the bags with a tag identified with a bar code unique for each retailer. In the

same way as with RVM, every month the total amount of the deposit that retailers have

returned to consumers is given back to them as well as 3 cents for each container returned

as compensation.

In both cases (machine and hand collection), containers are collected from outlets and

labelled to identify the source and type of material. When the returned containers arrive at

the counting plant with a label recording its origin, bottles are dumped into the machine to

quantify and assess the type of container and its material. The computer reads the bar code

on the package and identifies the type of material and its source. Once counted and

identified, containers are brought to a machine which compacts and separates containers

depending on the type of material. At the end of the process, compacted packs of high

quality raw material is ready for recycling. Its market price is much higher than the material



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obtained from kerbside collection because its quality is far superior, due to the lack of

contamination.

For the pilot project in Ireland, it would be best to implement both systems: RVM in

supermarkets and manual collection in smaller retailers in order to evaluate the different

methodology. They could be implemented either in different pilots or together in the same

one as it was done in Cadaques.

Containers to be included in the pilot

Different DRS programmes accept different kinds of containers. The most popular

containers collected include single use plastic (PET) and aluminium containers smaller than

3L, such as in the Spanish, University of Dundee or North Ayrshire Council cases. Others like

IKEA, Glasgow University or the organic farm in Whitmuir also included glass bottles and

coffee cups.

Historically, Tetrapak has been excluded from these programmes due to the technical

incapability of RVM to recognise them. However, Tomra has recently developed a new

machine able to recognise Tetrapaks, so they are now suitable to be included in the project.

If Ireland includes them during the pilot, it would be the pioneer in collecting Tetrapaks

through a DRS.

Other materials such as coffee cups are suitable to be included in the programme as they

were in Glasgow Caledonian University. James Cropper, an English company, recently

developed the technology needed to recycle this material.

The advantage of a DRS over others is that the materials collected are already separated so

its value in the recycling market is much higher than materials recollected by a kerbside

system.

The chart below indicates the price differences between poor quality mixed materials versus

separately sorted high-quality materials.

Brown

glass

Clear

glass

Green

glass

Mixed

glass

Aluminium

can

Clear and

light blue PET

Plastic bottle

Coloured PET

Plastic bottle

HDPE natural

Plastic bottle

HDPE mixed

colour

Plastic bottle

Mixed

34.17 37.11 28.89 18.61 775.28 245 41.9 309.2 144.4 64.4 Wasted materials average price, from last 9 months (Jan 2013 to Sep 2013), in £ per tonne (Source:

http://www.letsrecycle.com/prices)

Stakeholders

To create the most inclusive and effective DRS pilot, stakeholders should include:

Promoters: Environmental organisations, VOICE and CoastWatch, would be the primary

promoters and organisers of this pilot programme. In Spain, Reterna and in Scotland, Zero

Waste Scotland were the responsible promoters.



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Technological partners: Tomra provided the expertise for the reverse vending machines and

Rhenuse were responsible for central counting machines in Spain and Scotland. We

envision their involvement in the Irish pilot as well.

Local retailers: it is essential that we get buy in from as many retailers as possible to create

an effective programme. Retailers must agree to take back the containers and store them

until collected by recyclers.

Political stakeholders: political support is a key point to the success of this programme. In

both cases, Spain and Scotland, the project succeeded through the support of local mayors

and regional environmental departments.

Supports and actors against

These successful pilots have thrived because of the support of local authorities, i.e. the

mayor of the town, local council, university president, etc. The sector companies have also

supported the programmes by loaning the needed equipment and expertise. In the case of

Cadaques, many volunteers were involved in the pilot pulling it through the various hiccups.

In some cases, these programmes have had to cope with the opposition of big beverages

bottlers and distributors such as Coca-cola. Also kerbside collectors and REPAK consider DRS

programmes as competing with their activities.

Results

As a DRS programme has never been in place in Ireland, we must look to the results yielded

in Spain to understand the potential results in Ireland. (Results of the Scottish pilot

programme will not be available until March 2014).

Returns rate

Although Cadaques is fairly isolated, the DRS pilot was not a closed system and retailers

received drinks containers originally purchased from other shops that were not part of the

project. In order to gather accurate data on return rates, containers sold within the pilot

programme were labelled before they were sold with the deposit. The programme

promoters evaluated the returns rate of containers using two indicators.

• Global containers return: during the pilot programme, 105,901 deposits were

charged on beverages containers by the collaborating retailers, and 81,183 of them

were returned. Therefore, returned containers were 76.6% of the total containers

sold. However, the collection rate dramatically increased in the last month of the

trial. During the last month, the percentage collected increased to 82.03%, and

reached 91.23% in the last week. These return rates illustrate that returns rate never

stopped increasing throughout the whole pilot time.



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• Labelled containers return: during the two last weeks, an increase in the return rate

reached 66.83% of labelled containers in the last week. This increase shows that the

return level had not yet reached its potential and that returns were anticipated to

increase had the pilot lasted for a longer period of time.

Environmental indicators

A positive effect of a DRS is the reduction in the volume of recyclables and value recoverable

material being disposed in landfills. The Cadaques pilot estimated a reduction of between

18 and 25% in volume in the green bin and between 4.7 and 6.6% in the black bin.

According to the survey carried out among the citizens, most of the people recorded a

reduction in littering in the municipality, especially in streets but also on beaches, the sea

and in natural parks.

Economic facts (Cost)

Deposit and Refund pilot programmes launched in Scotland by Zero Waste Scotland with

the help of the Scottish Government’s Environment Secretary spent £900,000 on the

development of 8 different programmes throughout the country, averaging cost of around

£112,500 each, or €130,000.

The implementation of the pilot DRS in Spain had a positive economic impact in the local

economy. An evaluation was carried out regarding three indicators: variation of the

collection service costs, variation of the collection system incomes and variation of the

treatment costs.

• The reduction of the collection system expenses showed a decrease of between

€24,242 and €35,372 annually, which is 6.5-9.5% of the annual collection cost.

• Under the current system, these collection system operators received money from

recyclables sorted out of the black bin. Taking drinks containers out of the waste

stream reduced their sale of raw materials to recycling companies (between €1,240

and €1,767 annually). However, even with loss of this revenue, the net savings

realised by such collectors still yielded around €23,000 to €33,606 annually.

• Treatment costs would reduce between €1,742 and €2,420 annually, given that

1.91% in weight (6.62% in volume) of the waste would stop going to landfill.

Because a large volume of drinks containers would be recovered through DRS, littering

would decrease and associated cleanup costs would reduce correspondingly. The DRS pilot

quintupled the drinks container collection; it grew from 21% to 66.58% in three months.

Additionally, further investigation found that only 1 out of 10 beverage containers found in

the regular rubbish bin were charged with the deposit. Compared to the black bin and the

green bin, materials collected through DRS had the highest quality standards for the



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recycling industry in Spain. This better quality means an increase in materials price of

between 20 and 40% -depending on the materials- compared with the current collection

system rates.

Social response

In order to measure the social impact of the pilot programme, two surveys were conducted

-- one before the beginning of the pilot and another after it. These surveys revealed that

61% of respondents found the town cleaner after the pilot and 85% of them agreed with the

implementation of a real DRS program. The surveys concluded that there was a healthy

social acceptance to the programme.

Interviews with retailers, after the pilot, revealed that previous concerns about the lack of

space in shops and more workload had been avoided. Fears regarding a decrease in sales

were not realised and public image of participating shops improved. It is significant that all

participating shops owners now support the idea of implanting a DRS throughout the whole

country.

Conclusions and proposed scheme

Taking into account the Spanish and Scottish experience, we suggest the development of

three different pilot programmes in Ireland, in order to be able to evaluate different

methods and characteristics:

• Location: Trinity College, as a closed community with a micro economy that can

work as a micro model for national system; Croke Park Stadium, which has adopted

the three pillars of sustainability and has pursued green initiatives since 2008, has

the advantage of providing a close economic system; and a small town such as

Wexford or Dingle, with a population of 20,000 and 1,900 respectively, would

provide a better understanding of how a DRS might fare if implemented nationally.

• Deposit amount: A deposit of ten to twenty cents would be enough to ensure a

recovery rate of 70 to 90% of the containers, being small enough to discourage

fraud.

• Duration: The duration of the project would depend on the amount of money

available. Nevertheless, the longer the pilot, the more reliable the data would be,

given that the curve of recycling stabilises after one year of the project. However, 3-

6 months should be enough to get an idea of the success of such a project in the

community.

• Collecting system: it would be important to implement both RVM and manual

collection systems in each pilot to evaluate all the different possibilities.

• Containers taken: In the first stage, containers included in the programme should be

single use plastic (PET) and aluminium containers smaller than 3L, which are the



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most common containers used for take away drinks. In the future other kind of

containers such as glass bottles, Tetrapaks and coffee cups can be included.

• Stakeholders: Promoters (VOICE); Technological partners (Tomra can provide the

RVM and Rhenuse the central counting machines); Retailers (Local shops and super

markets in the case of the town, and the café and drinks shops in the Croke Park and

Trinity case); Political stakeholders (The support of the relevant authorities is

needed for the success of the programme in each case, i.e. the CEO of Croke Park

Stadium, the university president of Trinity College, and the local mayor of Wexford

or Dingle).

Container deposit and refund schemes have proven to be extremely successful in recovering

valuable and high quality material in other countries. These systems reduce waste, raise

recovery rates, save money, create jobs, and enjoy high public support. While a deposit and

refund system will be expensive to implement, its benefits greatly outweigh these costs. It is

estimated that these systems have net benefits of over €100 million.

According to the results of VOICE’s research and the findings of reports from the EU and all

over the world, VOICE recommends that Ireland implement a nation-wide beverage

container deposit and refund system.

environmental pillar submision to the regional waste...

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