Evaluation of the Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011 Evaluation of the Replacement Waste Management Plan for the Limerick/Clare/Kerry Region
Page 1 Replacement Waste Management Plan for the December 2012 Limerick/Clare/Kerry Region 2006-2011 LIST OF TABLES:...... 1 LIST OF FIGURES:...... 2 ABBREVIATIONS:...... 3 EXECUTIVE SUMMARY...... 4 1.0 INTRODUCTION...... 6 2.0 LEGISLATIVE UPDATE...... 7 3.1Targets...... 8 3.2 Inter-Regional Movements of Waste...... 8 3.3 Cost Recovery...... 8 4.0 WASTE PREVENTION...... 10 4.1 Waste Prevention Community/Household Level:...... 10 Fig 4.1 Household Waste Management & Generated per captia L/C/K REGION 2008-2010...... 11 Fig 4.2 Household Waste Managed- Regional comparison 2010...... 11 Table 4.2: Newspaper weekly circulation rate...... 11 Table 4.3: Radio Listenership...... 11 4.2 Waste Prevention –Home Composting...... 11 Table 4.4: Estimated quantity of Home Composted Waste, within the Region, 2005- 2011 (tonnes)...... 12 4.3 Waste Prevention at Schools Level...... 12 Fig. 4.3 No of schools with green flag...... 12 Table 4.5 No of Registered Green Schools, active Green Flags/annum and number of students influenced by programme...... 12
Page 2 4.4 Waste Prevention in the Commercial/Industry Sector...... 12 Table 4.6: RIWMO Involvement in Commercial/Business/Industry Events...... 13 Table 4.7: EAO Involvement in Business Events...... 13 4.5 Reuse at Business and Industry Level...... 13 4.6 Working with National Initiatives...... 13 Table 4.8: 2010 LAPN Programme - Events/Tourism/Sport Details...... 15 Table 4.9: 2010 LAPN Programme - Health Care Details...... 15 Table 4.10: 2010 LAPN Programme - In House Resource Efficiency Details....15 Table 4.11: 2010 LAPN Programme - Food Waste Prevention Details...... 15 Table 4.12: 2010 LAPN Programme - Networks for Waste Prevention...... 16 Table 4.13: 2011 LAPN Programme - Limerick City:...... 16 Table 4.14: 2011 LAPN Programme - Limerick County:...... 16 Table 4.15: 2011 LAPN Programme - Clare County:...... 16 Table 4.16: 2011 LAPN Programme - Kerry County:...... 16 Table 4.17: 2011 LAPN Programme - Additional Projects:...... 16 Table 4.18: 2012 LAPN Programme - Current Projects:...... 17 5.0 HOUSEHOLD WASTE MANAGEMENT...... 19 5.1 Waste Collection/Uncollected Waste...... 19 Table 5.1 No of Households signed up to a service...... 19 Table 5.2 Percentage of Households signed up to a service...... 19 Table 5.3 Tonnage of uncollected waste:...... 20 Table 5.4 Total Complaints and Litter Complaints in the Region...... 20 5.2 Re-use and Recycling...... 21 Fig. 5.1 Regional Household Recycling Rate Comparison...... 21 5.3 Organic Waste Collection...... 21 Fig. 5.2 Quantity of source segregated household biodegradable waste collected within the Region 2008-2011...... 22 ...... 22 5.4 Bring Banks...... 22 Table 5.5 Tonnage of Waste Collected at Bring Banks in L/C/K Region 2006 - 2010...... 22 5.5 Recycling Centres/Civic Amenity Sites/Transfer Stations...... 22 Table 5.6 Tonnage of Waste Collected at Recycling Centres in L/C/K Region 2006 - 2010...... 22 Fig. 5.3 Regional Recycling Rate Comparison...... 23 6.0 COMMERCIAL WASTE MANAGEMENT...... 24 6.1 Commercial and Industrial Waste Generation and Recycling...... 24 Fig. 6.1 Commercial and Industrial waste arisings per annum...... 24 Fig. 6.2 Commercial and Industrial waste arisings per Employee...... 24 Fig. 6.3 Commercial and industrial waste percentage recycling...... 24 6.2 Commercial Organic Waste...... 24
Page 3 Table 6.1 Tonnes of Source Segregated Commercial Organic Waste collected in the Region since 2008...... 25 Fig 6.4 Commercial Organic Waste collected within the Region 2008-2011....25 7.0 MUNICIPAL WASTE INCLUDING BIODEGRADABLE MUNICIPAL WASTE...... 26 Table 7.1 Municipal Waste Generated...... 26 7.1 Biodegradable Municipal Waste...... 26 8.0 CONSTRUCTION AND DEMOLITION WASTE MANAGEMENT...... 28 Fig 8.1 C&D Waste arisings within the Region 2004-2011...... 28 9.0 OTHER PRIORITY WASTE STREAMS...... 30 9.1 Hazardous Waste...... 30 Table 9.1 Breakdown of Quantity of Hazardous Waste Collected in Region 2008-2010...... 30 9.2 Waste Electronic and Electrical Equipment (WEEE)...... 31 Table 9.2 Quantity of WEEE Collected in Region 2008-2010...... 32 Table 9.3: WEEE Inspections in the L/C/K Region in 2010 (Source RMCEI Review Data)...... 32 9.3 End of Life Vehicles(ELVs)...... 32 Table 9.4: Quantity of ELVs collected within the Region for the period 2008 – 2011...... 33 Table 9.5: ELV Inspections in the L/C/K Region 2007- 2010 (Source RMCEI Review Data)...... 33 9.4 Tyres...... 34 Table 9.6: Quantity of Tyres collected within the Region for the period 2008 – 2011...... 34 Table 9.7: Tyre Inspections in the L/C/K Region in 2009-2010 (Source RMCEI Review Data)...... 34 9.5 Sludges...... 35 Table 9.8: Quantity of Sludge collected within the Region for the period 2008 – 2011...... 35 10.0 INFRASTRUCTURE...... 37 10.1 Bring Banks...... 37 Table 10.1 Bring Bank (BB) Numbers...... 38 10.2 Recycling Centres/Civic Amenity Sites/Transfer Stations:...... 38 Table 10.2 Recycling Centre Targets...... 38 10.3 Material Recovery Facilities (MRFs) and transfer stations:...... 39 Table 10.3 Waste Facility & Licence/Permit Processing Limit...... 39 10.4 Authorised Treatment Facilities (ATFs)...... 40 Table 10.4: ATFs in the L/C/K Region...... 41 Table 10.5 Current permitted processing capacity within the L/C/K Region....41 10.5 Composting facilities:...... 41
Page 4 10.6 Landfills:...... 41 Table 10.6 Remaining Landfill capacity Limerick/Clare/Kerry Region (October 2012)...... 41 10.7 Historic Closed Landfills:...... 42 10.8 Thermal Treatment Progress:...... 42 11.0 ENFORCEMENT & WASTE STATITCS...... 45 Table 11.1 Enforcement Activity in the Limerick/Clare/Kerry Region 2006 - 2010 (Source RMCEI Review Data)...... 45 12.0 SUMMARY...... 49 0Table 12.1 - Implementation Table (Min. Targets) specified in ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ & current status...... 49 Table 12.2 - Infrastructure Timetable specified in ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ & Current Status...... 50 Table 12.3 - Summary of ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ annual primary KPIs outcomes 2006- 2010...... 50 Table 12.4 - Summary of ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ annual secondary KPIs outcomes 2006-2010...... 50 13.0 OVERALL RECOMMENDATION...... 51 Table 13.1 - Summary of the policies listed in The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011...... 52 APPENDIX A...... 57 APPENDIX B...... 70 Table B1 Details of NIPP outcomes 2006-Sept 2009...... 71 Table B2: Key Performance Indicator Details NIPP 2006-2008...... 71 Table B3: Fostering Sustainable Behaviour Details...... 71 APPENDIX C...... 71 Table C1: Closed Landfill Draft Register Limerick/Clare/Kerry Region...... 72
Page 5 LIST OF TABLES: Table 4.1: No of Prevention Awareness Events held Annually in the L/C/K Region Table 4.2: Newspaper circulation rate Table 4.3: Radio Listenership Table 4.4: Estimated quantity of Home Composted Waste, within the Region 2005- 2011 tonnes) Table 4.5 No of Registered Green Schools, active Green Flags/annum and number of students influenced by programme Table 4.6: RIWMO Involvement in Commercial/Business/Industry Events Table 4.7: EAO Involvement in Business Events Table 4.8: 2010 LAPN Programme - Events/Tourism/Sport Details Table 4.9: 2010 LAPN Programme - Health Care Details Table 4.10: 2010 LAPN Programme - In House Resource Efficiency Details Table 4.11: 2010 LAPN Programme - Food Waste Prevention Details Table 4.12: 2010 LAPN Programme - Networks for Waste Prevention Table 4.13: 2011 LAPN Programme - Limerick City: Table 4.14: 2011 LAPN Programme - Limerick County: Table 4.15: 2011 LAPN Programme - Clare County: Table 4.16: 2011 LAPN Programme - Kerry County: Table 4.17: 2011 LAPN Programme - Additional Projects: Table 4.18: 2012 LAPN Programme - Current Projects: Table 5.1 No of Households signed up to a service Table 5.2 Percentage of Households signed up to a service Table 5.3 Tonnage of uncollected waste: Table 5.4 Total Complaints and Litter Complaints in the Region Table 5.5 Tonnage of Waste Collected at Bring Banks in L/C/K Region 2006 - 2010 Table 5.6 Tonnage of Waste Collected at Recycling Centres in L/C/K Region 2006 - 2010 Table 6.1 Tonnes of Source Segregated Commercial Organic Waste collected in the ...... Region since 2008 Table 7.1 Municipal Waste Generated Table 9.1 Breakdown of Quantity of Hazardous Waste Collected in Region 2008-2010 Table 9.2 Quantity of WEEE Collected in Region 2008-2010 Table 9.3: WEEE Inspections in the L/C/K Region in 2010 (Source RMCEI Review Data) Table 9.4: Quantity of ELVs collected within the Region for the period 2008 – 2011 Table 9.5: ELV Inspections in the L/C/K Region 2007- 2010
Page 6 Table 9.6: Quantity of Tyres collected within the Region for the period 2008 – 2011 Table 9.7: Tyre Inspections in the L/C/K Region in 2009-2010 (Source RMCEI Review Data) Table 9.8: Quantity of Sludge collected within the Region for the period 2008 – 2011 Table 10.1 Bring Bank (BB) Numbers Table 10.2 Recycling Centre Targets Table 10.3 Waste Facility & Licence Capacity Limit Table 10.4: ATFs in the L/C/K Region Table 10.5 Current permitted processing capacity within the L/C/K Region Table 10.6 Remaining Landfill capacity L/C/K Region (October 2012) Table 10.7 L/C/K region tonnage of waste accepted at landfill (2006-2011) Table 11.1 Enforcement Activity in the L/C/K Region 2006 - 2010 Table 12.1 Implementation Table ...... Table 12.2 Infrastructure Timetable Table 12.3 Summary’ of annual primary KPIs outcomes 2006-2010. Table 12.4 Summary of ‘annual secondary KPIs outcomes 2006-2010. Table 13.1 Summary of the policies Table B1 Details of NIPP outcomes 2006-Sept 2009 Table B2: Key Performance Indicator Details NIPP 2006-2008 Table B3: Fostering Sustainable Behaviour Details Table C1: Closed Landfill Draft Register Limerick/Clare/Kerry Region
LIST OF FIGURES: Fig 4.1 Household Waste Management & Generated per captia Fig 4.2 Household Waste Managed- Regional comparison 2010 Fig. 4.3 No of schools with green flag Fig. 5.1 Regional Household Recycling Rate Comparison Fig. 5.2 Quantity of source segregated household biodegradable waste collected Fig. 5.3 Regional Recycling Rate Comparison Fig. 6.1 Commercial and Industrial waste arisings per annum Fig. 6.2 Commercial and Industrial waste arisings per Employee Fig. 6.3 Commercial and industrial waste percentage recycling Fig. 6.4 Commercial Organic Waste collected within the Region 2008-2011 Fig. 8.1 C&D Waste arisings within the Region 2004-2011
Page 7 ABBREVIATIONS:
Page 8 AER - Annual Environmental Report ATF - Authorized Treatment Facility BMW - Biodegradable Municipal Waste C&D -Construction and Demolition CAS - Civic Amenity Sites CGPP - Cleaner Greener Production Programme CoD - Certificate of Destruction CoR - Certificates of Registration CSO - Central Statistics Office DECLG - Department of the Environment, Community and Local Government eAER - electronic Annual Environmental Report EAO - Environmental Awareness Officer EIP - Environmental Improvement Programme ELVs - End of Life Vehicles EPA - Environmental Protection Agency ERP - European Recycling Platform EWC - European Waste Code EWWR - European Week for Waste Reduction HR – High Risk IOSH - Irish Occupational Safety and Health KPI’s - Key Performance Indicators L/C/K Region – Limerick/Clare/Kerry Region LAPD - Local Authority Prevention Demonstration LAPN - Local Authority Prevention Network LCC - Limerick County Council LGMA - Local Government Management Agency LR – Low Risk MR – Medium Risk
Page 9 MRF - Material Recovery Facility NCDWC - National Construction and Demolition Waste Council NIPP - New Integrated Prevention Programme NTFSO- National Transfrontier Shipment Office NWCPO - National Waste Collection Permit Office NWPP - National Waste Prevention Programme NWR - National Waste Return PTUs - Pay-to-Use Waste Compactor Units RDF - Refuse Derived Fuel RIWMO – Regional Industrial Waste Minimisation Officer RMCEI - Recommendation providing for Minimum Criteria for Environmental Inspections RWMO – Regional Waste Management Office SME - Small and Medium Enterprises SMILE - Saving Money through Industry Links and Exchanges SOP - Standard Operating Procedure TFS - Transfrontier Shipment TRACS - Tyre Recovery Activity Compliance Scheme TWA - Tyre Waste Management Ltd UL - University of Limerick WCP - Waste Collection Permit WEEE - Waste Electronic and Electrical Equipment WFP - Waste Facility Permits WMA 1996 - Waste Management Act 1996 WTF - Waste Transfer Form
Page 10 EXECUTIVE SUMMARY The requirement to evaluate the Replacement Waste Management Plan for the Limerick/Clare/Kerry Region was introduced by the European Communities (Waste Directive) Regulations, 2011 and must be completed by the 31st December 2012. The evaluation process will be the decision making tool used to decide whether the current plan is adequate or needs to be revised or replaced. The 2006 Replacement Waste Management Plan for Limerick/Clare/Kerry Region specified the following overall targets:-
Recycling 45%
Thermal Treatment 41%
Disposal 14% Specific targets and key performance indicators were selected to further monitor the progress of the plan.
The scope for Local Authorities to recover costs for waste management activities is quite limited and in general no cost centre is fully self sufficient and this will have to be addressed in accordance with the polluter pays principle.
This evaluation examines progress made towards specific and overall targets taking account of factors influencing progress both internally and externally which either assist progress or create barriers to moving forward. These targets are outlined below:
Prevention
Prevention was a priority in the current plan and significant progress was made. Over €800,000 in grant aid was given by EPA to the Limerick/Clare/Kerry Region since 2006 and successful diversified projects were carried out in many areas including the following:
Airport/Shopping Contre/University/Construction Sites
Events/Toursim/Sport
Healthcare
In-house resource efficiency
Food Waste Prevention
Networks for Waste Prevention
Green Town Projects
Page 11 Green Festivals
Community based Projects.
In addition to this Environmental Awareness Officers and the Waste Minimisation Officer carried out a wide variety of prevention events and completed substantial media and other print campaigns. Campaigns were targets at various levels:
Household prevention events & media campaigns
Home composting and master composting workshops & print campaigns
Green Flag Schools
Establishing business network & company visits
Annual seminars for industry & Business
Newsletters & Poster Campaigns.
The key performance indicators in the prevention area have shown reduction in waste managed per capita and waste managed per employee but are influenced positively be the economic downturn.
Uncollected Household Waste
In 2011 42% of households in this Region were not signed up to a waste collection service and therefore the management of this waste cannot be accurately accounted for and requires assessment and action.
Recyling Household recycling was at 13.9% in 2004 and now has reached 42%. Commercial recycling has increased to over 60%. Significant recycling awareness campaigns have been carried out over the last few years.
Organic Waste Organic waste collection for household and commercial waste only began in this Region in 2008 and now over 8, 000 tonnes of organic waste has been selectively collected per annum. This was assisted by awareness campaigns and the introduction of the commercial food waste Regulations
Priority Wastes
Page 12 The European Union identified a number of priority streams for waste including construction & demolition waste, hazardous waste, waste electrical & electronic equipment, end of life vehicles and tyres.
The construction and demolition waste was the biggest waste stream in the region in 2006 but the effect of the economic downturn has reduced the generation rates of this waste by 81%.
Hazardous waste data collation only began in 2008 but commercial and household hazard waste reduction campaigns were organised in this Region
New legislation was introduced for waste electrical & electronic equipment and all targets were met, the compliance schemes were very effective.
New legislation was also introduced for end of life vehicles and targeted enforcement in this area has contributed to regularisation of the activities and improved data collection.
Tyre waste has been highlighted as an issue over the last two years, enforcement continues but there are difficulties tracking tyre movements even with two compliance schemes.
Infrastructure Recycling infrastructure is well developed and meets current demand even though all bring bank and recycling centres targets were not met. Some organic waste infrastructure has been developed within the Region with further developments being considered by the private sector. The landfills in this Region are due to close at the end of 2013 and no progress has been made on alternative disposal options for residual waste.
Enforcement & Waste Statistics Enforcement teams in the Region are well established and extremely effective in dealing with national and local waste enforcement priorities. The collation of waste statistics has been automated in this plan period resulting in improved waste data.
Page 13 Recommendation It is recommended that the current plan needs to be replaced with a new plan to take account of the new configuration of Waste Regions and that the findings of this evaluation be incorporated into the New Plan.
Page 14 1.0 INTRODUCTION
The EU Waste Framework Directive was transposed into Irish Law in March 2011 with the passing of the European Communities (Waste Directive) Regulations, 2011. The requirement to evaluate the Replacement Waste Management Plan was introduced by this Directive and transposed into the Waste Management Act 1996 (WMA 1996) by the amendment of Section 22 of this Act.
Regulation 8 of EC (Waste Directive) Regulations, 2011states the following:-
Waste management plans and the hazardous waste management plan in existence at the commencement of the Regulations of 2011 shall be evaluated by 31 December 2012 and, consequent on any such evaluation, where appropriate, be revised to be brought into line with the requirements of the Waste Directive.
The Replacement Waste Management Plan 2006-2011for the Limerick/Clare/Kerry Region (referred to as “the plan” in proceeding document) was in place at the time of publication of the new Regulation and therefore is required to be evaluated by the end of December 2012. The evaluation process will be the decision making tool used to decide whether the current plan is adequate or needs to be revised or replaced.
The evaluation that follows will inform the Local Authorities in this Region on the effectiveness of the policies in the current plan as well as assessing the requirements of the new legislation such as the inclusion of the waste hierarchy, so an informed decision on whether the plan needs to be revised or replaced can be made.
The L/C/K evaluation process will consider the following:-
1. How have policy objectives been implemented?
2. What is the status of the targets set out in the plan?
3. What are the barriers preventing the successful implementation of the objectives?
External factors including the implementation of the recently published Department of the Environment, Community and Local Government (DECLG) documents, “Waste Management Policy in Ireland –A Resource Opportunity” (July 2012) , budget constraints and control by the private sector will need to be considered in assessing the factors that have had an impact on meeting the objectives of the plan and future plan .
Page 15 The 2011 European Commission communication-Roadmap to a Resource Efficient Europe states that by 2020 waste should be managed as a resource with the decoupling of economic growth with the use of resources. The recent DECLG waste policy reflects this European communication.
In accordance with the EC (Waste Directive) Regulations, 2011 life cycle analysis is now incorporated into waste management to ensure best overall environmental outcomes and is the only justification for deviating from the waste hierarchy.
In the L/C/K Region domestic waste collection has been more than 90% privatized for the past number of years and this had a significant effect on implementation of household and commercial waste plan policies.
Page 16 2.0 LEGISLATIVE UPDATE
RPS Consultants prepared the waste evaluation legislation document. The document contains a non-exhaustive list of key waste regulations which have been introduced since the making of the previous plan. The waste regulations identified are considered to be the most relevant in terms of the evaluation process and the subsequent waste plan review process. The document contains a summary of each regulation along with selected extracts which identify key Local Authority requirements.
A copy of the waste evaluation legislation document is available in Appendix A of this report.
Page 17 3.0 OVERALL POLICY STATEMENT
The four Local Authorities in the L/C/K Region, Limerick County, Limerick City, Kerry County and Clare County agreed in 1999 to prepare a joint Waste Management Plan and the first plan was published in 2001. This plan was reviewed in 2004/2005 and a joint Replacement Waste Management Plan was made and published in 2006 and the overall targets of the replacement plan were set as follows:-
3.1Targets
Recycling 45%
Thermal Treatment 41%
Disposal 14%
In the first plan for the Region, introduction and improvement of recycling was the key component but the replacement plan prioritized waste prevention and minimization at source, as key strategy components, focusing on delivering more tangible success in waste reduction. The policy for the Region is an integrated waste management policy with priority assigned in accordance with the EU Waste Management Hierarchy that is now transposed into Irish Law.
The policy takes cognizance of all relevant and pending legislation recognizing new and emerging technologies including thermal treatment options as well as considering priority wastes:-
Construction and Demolition (C&D) wastes
Hazardous Waste
WEEE- Waste Electrical and Electronic Equipment
ELVs- End of Life Vehicles
Tyres
The overall policy also promoted sustainable waste management in all sectors including commercial and industrial sectors.
3.2 Inter-Regional Movements of Waste.
The Government’s policy document ‘Taking Stock and Moving Forward’ (2004), recognized that the proximity principle has been interpreted too severely by some planning authorities and that some planning authorities have been too
Page 18 literal in their interpretation of waste plans. The policy statement confirms that each Region has to take responsibility for its own waste.
The Section 60 Policy Guidance Note as issued by the Minister for Environment, Heritage and Local Government on May 3, 2005 states “the application of the proximity principle does not entail interpreting administrative waste management planning boundaries in such a manner as to inhibit the development of waste infrastructure which will support the attainment of national waste management policy objectives through the rational development and use of such infrastructure”.
The Policy in the plan is as follows:-
While it is recognised that there should be flexibility with respect to the movement of waste across Regional boundaries, the proximity principle must be taken into account in the interest of the environment.
On the ground the reality is that waste from the L/C/K Region moved freely throughout the Republic of Ireland and the market place price is considered to be the primary driver in the Region for selection of destinations. It should also be recognised that not all the infrastructure requirements were met within the Region resulting in waste moving outside the Region for processing.
In some cases even though there was ample residual landfill void space available in the Region residual waste was landfilled outside the Region and destination locations were chosen only on the basis of the gate fee charges.
3.3 Cost Recovery
The EC (Waste Directive) Regulations 2011 amends Section 31 of the WMA 1996 to state the following: In accordance with the polluter pays principle, the costs of waste management shall be borne by the original waste producer or by the current or previous waste holders.
The scope for Local Authorities to recover costs for waste management activities is quite limited and in general no cost centre is fully self sufficient and this will have to be addressed in accordance with the polluter pays principle. Current cost centre details are summarised below.
Enforcement & Regulation: Staff and some activities of the enforcement staff are grant aided until 2014 through the annual grant from the DECLG funded by the environment fund. Facility permitting fees and investigation fees also contribute to funding this cost centre. End of Life Vehicle (ELV) registration fees assist in the funding of one technical staff member.
Page 19 Civic Amenity Sites (CAS): Funding of CAS varies throughout the Region with some CAS charging a gate fee and others not. The CAS are also funded by a subvention from DECLG and a subvention from Repak for the packaging. When all income and outgoings are calculated there is an significant overall charge to the Local Authorities for running CAS.
Bring Banks: Costs are generally approximately 50% recovered for bring banks between the subvention from Repak and the income from the textile banks.
Street Cleaning: Street cleaning fees should be recoverable from rate charges from most of the Local Authorities in the Region.
Historic Closed Landfills: The Minister in April 2012 agreed with the European Commission to provide funding for investigation and remediation of landfills in operation between 1977-1997, from voted expenditure as necessary to support works required to bring the European Court Judgement case (ECJ 494/01) to a close.
Landfill Management: Landfills are the most difficult waste management infrastructure in the Region to manage as the fixed costs in the landfill are quite high even when the volumes of incoming waste vary. The gate fees at landfill sites reduced by over 120% in the last few years making it increasingly more difficult to ensure that landfills do not run up deficits from an original position of generally working in surplus. A number of factors have affected cost recovery at landfills over the last number of years and these includes:-
1. Increase in the landfill levy
2. Limits on Biodegradable Municipal Waste (BMW) permitted to landfill under EU Landfilll Directive
3. Managing increase leachate levels with limited disposal options
4. Financial provisions for the on-going maintenance, monitoring and management including closure and subsequent after-care of the landfill
In general funding for Local Authority operated waste infrastructure has been diminishing over the last few years and as subventions and contributions decrease the Local Authorities may seek funding provision from the private sector to assist in the management and maintenance of household recycling facilities.
Page 20 4.0 WASTE PREVENTION Under the EC (Waste Directive) Regulations, 2011the first definition of waste prevention has been transposed into Irish Law by amending the WMA 1996 definitions:
Prevention means measures taken before a substance material or product has become waste that reduce-
a) The quantity of waste, including through the re-use of products or the extension of the lifespan of products, b) The adverse impacts of the generated waste on the environment and human health or c) The content of harmful substances in materials and products.
The EC (Waste Directive) Regulations, 2011establishes that waste prevention should be the first priority for waste management and for the first time the waste hierarchy is established in Irish Law. In terms of prevention it can be redrawn in the new waste hierarchy as shown, with all items below the line not considered to be prevention options. So this is clear picture of what prevention is.
In the plan for the L/C/K Region the policy on prevention was as follows:-
The Local Authorities will commit to prioritising waste prevention and minimisation as outlined in the EU and Irish Waste hierarchy
The objectives of the current plan are based on the continuation of prevention awareness already achieved in the 2001 plan and to continue to work with national initiatives as shown in the objectives below from the current plan Chapter 15.2:-
Environmental Awareness Officers shall continue to promote waste prevention and minimisation at the household and community level
Target waste prevention and minimisation at the business (SME) level
Ensure the Waste Management Plan is implemented over the Plan period
Page 21 Continue to work with industry on waste prevention and minimisation
Local Authorities will continue to work in tandem with national initiatives including the Race Against Waste campaign and the National Waste Prevention Programme including the LAPD programme
Local authorities already operate a comprehensive schools awareness programme and will continue build upon progress already made
The L/C/K Region worked consistently over the life of the plan to implement the prevention and minimisation objectives outlined in the plan and to meet the targets set.
4.1 Waste Prevention Community/Household Level:
A wide variety of prevention events were held across the Region over the last six years and these included workshops, presentations, open days, environmental competitions, real nappy days webpage initiatives, display stands at shows, waste minimization days and a number of radio and newspaper articles to assist with the prevention message.
The target set in the plan was as follows:
Awareness initiatives focussing on ways for householders to prevent waste will be organised at least twice a year twice a year
These events were prepared and organised by the Environmental Awareness Officers (EAOs) in the Local Authorities and the target was achieved and superseded in all Local Authority areas in this Region. A summary of the events is shown below.
Table 4.1: No of Prevention Awareness Events held Annually in the L/C/K Region – Jun Total No. e of 200 Opportun 6- ities to Jun June June June June influence e 2007- 2008- 2009 2010- Total people Local 200 June June -June June No of Authority 7 2008 2009 2010 2011 Events Limerick 2,320 City 2 5 9 6 7 29
Page 22 Limerick 2,160 County 4 6 7 5 5 27 Kerry 2,560 County 3 5 9 6 9 32 Clare 2,800 County 9 9 6 5 6 35 Total 123 9,840
Note: In the Region it is estimated that on average 80 people attended organised prevention awareness events.
In addition to the organised prevention awareness events the EAOs within the Region also participated in a number of events with significantly larger public attendance i.e. county fairs, agricultural shows, markets etc. It is estimated that there was an opportunity to influence in excess of 56,000 personnel at these events.
In addition to this a number of printed prevention awareness campaigns were prepared and funded by the Regional Waste Management Office (RWMO) such as the leaflets demonstrated below.
In addition each of the Local Authorities administers the Local Agenda 21 grant aid in their own functional area. A significant number of these projects each year relate specifically to waste management including composting and form part of the National Waste Prevention Programme (NWPP).
Page 23 The primary key performance indicator (KPI) selected in the plan for measuring the effectiveness of these campaigns and prevention awareness activities is the household waste generated per capita.
Household waste per capita is calculated as either managed or generated. The quantity of household waste managed is taken as household waste collected at the kerbside, CAS, Bring Banks, WEEE brought to retailers and an estimate of home composting. The waste generated per capita figures includes all of these as well as an estimate for uncollected waste. Over the last number of years the calculation within this Region was based on waste managed whereas earlier years the calculation was for generated waste only.
Figure 4.1 below indicates that the household waste managed within the Region has decreased over the last number of years and is now at 295 kgs per capita and compares well with the national 310kgs per capita average reported in the 2010 Environmental Protection Agency (EPA) National Waste Report.
The household waste generated, which includes the uncollected waste, has shown a slight increase in 2010 due to an increase in the estimated uncollected waste for the Region in 2010 (refer to Section 5.1).
Fig 4.1 Household Waste Management & Generated per captia L/C/K REGION 2008-2010
The waste managed per capita indicator also demonstrates a strong performance when compared to other Regions as shown below.
Page 24 345 350 336 339 340 326 330 320 303 304 310 295 300 kgs/capita 290 280 270
Fig 4.2 Household Waste Managed- Regional comparison 2010
The marked decrease in personal consumption in the last number of years has been influenced greatly by the economic downturn and has a direct influence in waste generation per capita. However even prior to the commencement of the economic downturn, the waste managed per capita was declining which could indicate that education and awareness prevention campaigns and projects were starting to have a positive impact on waste generation
Extensive media campaigns were undertaken by the EAOs using local press. It is estimated that 582 media releases were issued from 2006-2011 reaching significant numbers of readers in that time. Table 4.2 below shows the weekly circulation rates of weekly Regional papers published within this Region.
Table 4.2: Newspaper weekly circulation rate Newspaper Title Weekly Circulation Rate Clare Champion 15,742 Kerryman 19,886 Limerick Leader 14,851 Limerick Post 52,817 Total 103,296
Source: ABC Circulation Figures (Jul-Dec 2011 except Kerryman Jan-Jun 2011)
Established facts indicate that Regional papers are read between 4 and 7 times as they are kept in people’s homes for at least 7 days or longer. Therefore based
Page 25 on the above weekly circulation rates there is an opportunity to influence over 400,000 members of the public through each media release.
Radio campaigns have also proved very successful in communicating best waste management practice. Listenership per day for the radio stations in the Region is estimated at 255,000 listeners. EAOs have been proactive in gaining slots on prominent shows and news slots. 192 interviews were undertaken during the plan period (2006-2011). A conservative estimate of 50% tuning into the interviews has been assumed.
Table 4.3: Radio Listenership Radio Station Listeners per day % Market share
Radio Kerry 60,000 49
Clare FM 43,000 47
Limerick's Live95FM 69,000 45
Spin SW 83,000 33 Total listeners per day 255,000
Source: JNLR/Ipos MRBI 2012/2 and ilevel.ie
4.2 Waste Prevention –Home Composting.
Composting is the decomposition of organic material with over one third of household waste compostable. Home composting is suitable for garden waste and food waste of vegetable origin and the length of time it takes to compost varies depending on the mix of green and brown materials, moisture and air content. The average home composting time is 3-4 months. The compost produced in the home composter can then be put to beneficial use within the domestic garden and the nutrients are returned to the soil.
The plan included the following objective under Chapter 15.5
To achieve the 2010 target as set out in the National Biowaste Strategy through a combination of source separated collection and appropriate treatment, combined
Page 26 with collections with other waste streams, with appropriate Mechanical Biological Treatment, home composting and green waste recycling centres The following target was set for home composting in the plan: Minimum of 35% coverage for home composting of garden waste and food waste of vegetable origin at an average yield of 40% of biowaste arisings – targeted particularly in suitable areas where separate collection not in place; Home composting workshops were held at least 3-4 of times per year in every Local Authority and an information mini guide was developed and distributed widely at these events. In the early years home composting units were generally sold at these events but these have become widely available on the open market in recent years and are no longer supplied by the Local Authorities.
A Master Composter programme was developed by the Stop Food Waste initiative (led by the EPA). In this Region programmes were run in Kerry and jointly between Clare and Limerick City. The programmes included training sessions and lectures about different forms of composting and three demonstration sites have been set up in the following areas:
1. Deans Lane, Tralee, County Kerry
2. Shannon, County Clare
3. O’ Brien Park, Clare Street, Limerick City.
Accurately assessing the number of households participating in home composting within the Region is not possible due to availability of home composters across the retail sector, and feed-back is as yet unavailable on the actual usage of sold composters.
As part of the annual National Waste Returns (NWR) Local Authorities are required to estimate the quantity of waste which is home composted and Table 4.4 below details the estimated quantity of home composted waste, within the Region, for the years 2005 – 2011
Table 4.4: Estimated quantity of Home Composted Waste, within the Region, 2005- 2011 (tonnes) Waste Type 2005 2006 2007 2008 2009 2010 2011 Estimated quantity of Waste Home Composted (tonnes) 2,727 3,606 2,896 2,925 3,831 3,446 4,084
Page 27 The above table shows a varying trend year-on-year in relation to the quantity of home composted waste generated. However it should be noted that the methodology used to calculate the quantity of home composted waste needs to be agreed nationally as even Local Authorities within this Region were using different methods up until recently.
4.3 Waste Prevention at Schools Level.
The Green Schools programme is a collaboration between schools, An Taisce and the Local Authorities. Green-Schools, known internationally as Eco-Schools, is an international environmental education programme, environmental management system and award scheme that promotes and acknowledges long-term, whole school action for the environment. They uptake of green schools in this Region has increased annually and the Green School programme is audited bi-annually. The key performance secondary indicator is the number of schools with active Green Flag status. According to the An Taisce statistics seventy-two schools were awarded Green Flags in 2004 and has now reached 313 in 2012 indicating a very active programme over the last number of years.
Number of Schools with Green Flag
350 300 250 200 Number of Schools with Green Flag 150 100 50 0 2004 2005 2006 2007 2008 2009 2010 2011 2012
Fig. 4.3 No of schools with green flag
The focus of the green schools programme is theme based. There are seven themes - Litter and Waste Energy, Water, Travel, Biodiversity and Global Citizenship (emphasis on litter and waste). As the first phase of the programme concentrates on litter and waste almost all schools which register are most likely to get involved in this part of the programme. Table 4.5 below shows an estimate of the high numbers of students that were influenced annually by the
Page 28 Green Schools programme, and the huge success that this programme has and continues to be.
Table 4.5 No of Registered Green Schools, active Green Flags/annum and number of students influenced by programme Year 2004 2005 2006 2007 2008 2009 2010 2011 2012
No of Registered Green Schools 207 259 294 322 360 380 411 446 451 No of Registered Green Schools - with Green Flag 72 92 117 156 198 224 257 283 313
Total No. of Students influenced 31,69 38,22 49,13 53,54 58,22 61,00 65,47 70,60 71,24 per annum 1 8 8 4 5 3 8 5 3 Note: Information above obtained from An Taisce
As the EC (Waste Directive) Regulations, 2011 establishes that waste prevention should be the first priority for waste management; it is paramount that the waste prevention message is prioritized in the Green Schools programme.
4.4 Waste Prevention in the Commercial/Industry Sector
The most relevant target for commercial waste target set out in the plan under Chapter 15.2 is:-
Seminars, workshops and awareness initiatives focusing on waste prevention and minimisation for SMEs will be run at least annually
Visits to Businesses
From 2003 to-date, the Regional Industrial Waste Minimisation Officer (RIWMO) has visited a total of 355 companies. Many visits lead to environmental awareness events for employees and to involvement in the company’s waste reduction programme. With the inclusion of employee awareness events, the total number of people met through all these visits comprises approximately 500
Page 29 and the KPI in the plan for this area is the number of company visits and the baseline 2004 figure of 120 has been well exceeded now.
Awareness Events
Over the course of the current Plan, the RIWMO has organised or participated at a variety of business events, including the annual Regional Environmental Forum organised jointly by the RWMO and Enterprise Ireland. The RIWMO uses opportunities to set up a stand at Regional business exhibitions and has participated in student open days and lectures. The following table is a summary of the numbers of events and attendees over the current Plan period.
Table 4.6: RIWMO Involvement in Commercial/Business/Industry Events No of Events Average No of Total attendees attendees 23 Seminars 33 760 13 Exhibitions 80 1,040 11 Student 175 1,925 Events
EAOs also work with the business sector in pursuit of best environmental practice, and work closely with the RIWMO. EAOs have been involved in organising and also been speakers at external events. Table 4.7 details the number of business events that EAOs participated in and the number of attendees at these events
Table 4.7: EAO Involvement in Business Events No of Events Average No of attendees Total attendees in the Region 29 70 2030
Awareness through Business Networks
The RWMO has established links with several business associations and support organisations throughout the L/C/K Region. These include Chambers of Commerce, Supply Network Shannon, Shannon Development, Enterprise Ireland, Enterprise Boards, Leader Groups and Skillnets. Contact with the hospitality
Page 30 sector was strengthened through the Green Hospitality Awards programme, for which the RWMO provided part funding from 2007 to 2009 and which the Region has continued to promote since the programme became nationwide as funded by the EPA.
Some of these business network activities comprised specific waste prevention and awareness programmes, such as the RWMO-lead Green Mentor Programme which received funding under the EPA’s Cleaner Greener Production Programme (CGPP) and which involved businesses throughout the Region. The RWMO also took part in the UL-lead Eco-Industrial Network which also received funding from EPA.
Circulation of news and publications
By June 2012, the email business circulation list established by the RWMO has expanded to 665. At a minimum a further 600 people are reached through email links with other business networks. RWMO publications and other environmental news items have been circulated by email as well as distribution at events, including the Regional newsletter ‘Managing Waste in Business’ as well as a series of information guides and leaflets covering the prevention and
management of business waste.
4.5 Reuse at Business and Industry Level
The RIWMO has been involved in many activities to raise awareness amongst the commercial and industrial sector and some examples are outlined below:-
Promotion of Reuse through Case Studies and Events
Among the case studies used for events and publications, there were many examples of reuse- e.g. use of reusable packaging in incoming materials and reuse of on-site waste packaging in outgoing product. Speakers from companies shared their success stories on how they reduced costs through environmental improvements, which invariably always included the concept of reuse along the supply chain. Business events and publications also included presentations on initiatives under Local Authority Prevention Demonstration Programme (LAPD)
Page 31 and subsequently Local Authority Prevention Network (LAPN), which have provided many examples of reuse.
Promotion of re-use / exchange websites
From mid-2011 to-date, the RWMO has provided part funding to the ‘Saving Money through Industry Links and Exchanges’ (SMILE) programme. SMILE activities for the Region comprise networking exchange events, members’ direct logging activities on the SMILE website and regular promotion of the scheme to a wide business database. SMILE to-date has 542 members, of which 189 are from the L/C/K Region.
The RWMO also supports the FreeTrade Ireland reuse website through direct funding and by providing promotion and publicity on this facility that is available free of charge to the public. Other local reuse websites are also promoted through links on the website www.managewaste.ie.
Business Network Activities
The RWMO promoted and participated in the Supply Network Shannon reuse initiative ‘The Pallet Exchange’ which received funding under the EPA’s CGPP.
The RIWMO became involved in an Industrial Symbiosis Network which also included the Mid West Regional Authority, the Dublin Regional Authority, EPA, Supply Network Shannon and Macroom-E. The focus was ‘One company’s waste is another company’s resource’. An Industrial Symbiosis event that was run in Limerick included a speaker from FreeTrade Ireland Exchange website, and the Mid West Regional Authority who presented the results of a company survey conducted on behalf of the Industrial Symbiosis Network.
It is acknowledged that the Region did not meet the target of having at least two reuse/recycling workshops per year to be held by each Local Authority for the industry and business sector. However, during the course of the plan period, the Region adopted the view that it would be more effective to focus on promotion of reuse through involvement in business reuse networks and in the promotion of resource exchange websites and associated networking activities.
4.6 Working with National Initiatives
Having the objective of working in tandem with the NWPP and including the LAPD programme in the plan has ensured that prevention has been a cornerstone of awareness and education across all socio-economic sectors in the Region during the plan period.
This Region has promoted the national programme of greenbusiness.ie by circulation of information to business contacts and by inviting speakers from greenbusiness.ie to speak at a number of the annual Regional seminars
Page 32 organised jointly by the RWMO and Enterprise Ireland. Representatives of the programme also spoke at some other local events which the RWMO helped organise, such as Enterprise Board events or local business network events.
The Green Hospitality Programme initially received funding from the RWMO – from 2007 to 2009. Since its establishment as a nationwide EPA-funded programme, this Region continues to promote it through ongoing notifications to individual businesses and business networks.
The RWMO has promoted among business and network contacts, details of each call made under the EPA’s CGPP. As well as having been a participant under CGPP under the Green Mentor Programme, the RIWMO has encouraged businesses to apply under the calls for CGPP proposals, and has promoted case studies arising from previous CGPP projects.
The Region applied to participate in the LAPD programme as the plan was adopted and the Region was successful in gaining funding for an initial three year programme which ran from the autumn of 2006 till September 2009.
Further funding has been secured since then and the L/C/K Region has played a significant role in shaping the current LAPN approach through participation in the national co-ordination group for the LAPN programme. In total the RWMO has received over €800,000 in funding for prevention during this pan period
4.6.1 LAPD
Participation in the LAPD programme presented a unique learning experience for personnel in the Region. Prior to LAPD the primary focus of communication programmes and business outreach had largely centred on segregation and recycling. Establishing a programme based instead on waste prevention, which was to be achieved within a defined time period and measured through a series of KPIs linked to external organisations was both exciting and daunting.
The EPA established specific requirements to be met in order to be eligible for LAPD funding. These requirements included that the RWMO and Local Authorities identify project partners and ensure their commitment in advance of securing funding. The LAPD project proposal drawn up by the EAOs was very ambitious in its initial scope.
The LAPD project was delivered by a number of project personnel; a project officer was recruited and positioned in the RWMO. The role of the project officer was to ensure that the objectives of the original programme were delivered or if deviated from to ensure there was adequate justification. The EAO’s provided vital support to the delivery of the LAPD project; 25% of their time over the three year period was dedicated to delivering the programme. EPA funding was for 75% of costs with the 25% contribution made up in time from EAO as well as other Local Authority and RWMO staff.
Page 33 Delivering a prevention project in each Local Authority area would also have been far more difficult to deliver without the assistance of the EAO’s and their extensive knowledge of local issues and local personnel. 4.6.1.1 LAPD ACTIONS & RESULTS
The delivery of a Regional project spanning four Local Authorities allowed for a variety of different projects approaches and methodologies to be employed on each of the initiatives. The focus overall was on solid waste prevention initiatives and the tools employed to conduct and monitor the projects used were largely the same although there were four separate initiatives. The tools included waste, energy and water auditing methodologies and a range of communication tools to deliver awareness campaigns. The most significant results from the programme which was called the New Integrated Prevention Programme (NIPP) are listed in Appendix B, but in synopsis the programme had a strong focus on the following areas:
Reducing paper consumption in large administrations such as Universities & Local Authorities
Reducing C&D waste in urban sites
Preventing household waste in urban apartments
Preventing retail waste in a shopping centre with shared waste management facilities
Preventing waste and establishing resource efficiency benchmarks for a Regional airport.
The specific details including environmental results and financial savings are detailed in Appendix B (Table B1).
4.6.1.2 Key Performance Indicators (KPI’s)
A number of KPI’s were developed for the programme and where possible these were monitored at the outset of NIPP in 2006 and compared again at the end of the intervention period (Dec 2008 to Jan 2009). The KPI results are detailed in Appendix B (Table B2)
4.6.2. LAPN
The LAPN Programme commenced in September 2009 with a re-focused brief. The EPA as funding agent for the programme recognised that a great deal of progress in establishing and delivering an integrated prevention programme had been made as a result of the L/C/K Region engaging with LAPD particularly in the up-skilling of RWMO and Local Authority staff in the area of delivering prevention initiatives. In total 5 staff members and one community agent have
Page 34 received Prevention Training via the Clean Technology Centre and the Cork Institute of Technology during the plan period.
The LAPN approach took a less prescriptive stance to the delivery of prevention initiatives with a greater focus on building capacity across the Region rather than working with a narrow band of organisations. This approach has been very successful and coupled with improved capacity to deliver prevention in key personnel the number of initiatives undertaken was greatly enhanced since LAPN commenced.
The continuation of funding to cover the Waste Prevention officers salary has ensured that a full time post has been designated to driving resource efficiency and waste prevention and the importance of this is shown in the tables below by the large number of initiatives undertaken and the successful results for the Region since September 2009. Again, it should be stressed that the EAO’s also play a critical role in the development and delivery of the LAPN programme.
The LAPN Programme was funded annually in 2010, 2011 and 2012; with no guarantee of a roll-over from year to year, this has led to uncertainty at times and also to short delays in commencing programme delivery at the beginning of each calendar year.
The LAPN actions and results for 2010 are detailed in Tables 4.8-4.12 on a sectorial basis as follows:-
Events/Toursim/Sport
Healthcare
In-house resource efficiency
Food Waste Prevention
Networks for Waste Prevention
Fostering Sustainable Behaviour projects were also carried out in 2010 and the details of these are provided in Appendix B (Table B3)
The LAPN actions and results for 2011 are detailed in Tables 4.13-4.16 per Local Authority. Additional projects carried out in 2011 are detailed in Table 4.17.
2012 current projects are detailed in Table 4.18
Page 35 2010
Table 4.8: 2010 LAPN Programme - Events/Tourism/Sport Details Locati Work Carried Out on Thomo Annual rd nd Park Introduction of 3 bin for corporate/kitchen area visitors for 2010 = Introduction of segregated bins in all spectator areas 366,788 Staff training on environmental awareness
Waterless urinals extended to all toilets & restrictors placed in each cistern
Refurbishment of generators leading to reduction in diesel consumption of 50%
Outreach to support local hostels with food donations
Extensive research & discussion with Diageo & Catering Contractor Masterchef to introduce compostable drink cup for bar sales at concerts/sporting events Cliffs of Annual Moher Involvement of catering tenants in waste prevention visitors initiative: data collection underway on food waste using generated per customer with a view to producing a visitor relevant benchmark for this venue centre 800,000 Introduction of locally sourced food & more emphasis
Page 36 on Irish products on the Long Dock Menu
Installation of Dyson Air Blades & Green Washroom initiative
Participation in EWWR by hosting BatucaMob Killarne Annual y Waste Audit of Muckross House Restaurant, Visitors to Nation agreement with Trustees to develop waste prevention the park > al Park plan 1 million Reduction in water consumption of 50%
Reduction in waste to landfill of 40% & cost by 60%
Development of an energy charter for NWPS staff
Investigation into AD as an alternative treatment for waste water & sewage
Inclusion of sustainability criteria in new contracts for catering tenants UL Arena Arena Development of Green Arena Initiative was rolled out users > in 2011 800,000 per year. Assistance to management in the development of sustainability criteria for in inclusion in third party agreements for special events.
Table 4.9: 2010 LAPN Programme - Health Care Details
Location Work Carried Out Milford Care Centre Staff training, establishment of green team Roll out of 3rd bin
Page 37 Food Prevention Awareness restaurant & pantry staff
Water auditing investigating opportunities for rain water harvesting for horticultural purposes
Participation in EWWR HSE Non Acute Collection of data on food waste arisings with a view to Services establishing a suitable bench mark for these establishments.
Assistance provided to HSE staff on Food waste regulations and development of “Top Tips” for food waste prevention.
Table 4.10: 2010 LAPN Programme - In House Resource Efficiency Details
Locatio Work Carried Out n Limerick Sustainable Parks Project: site clear out complete, composting bays City established. New “shed” almost complete with rain water Council harvesting ability & greater energy efficiency. Reduction in waste to landfill: clean organic street sweepings (leaves) now composted. Investigating river water abstraction. Trial underway with alternatives to peat & plastic pots. Ongoing review of energy consumption in relation to glass houses & polytunnel’s Kerry County Council Grass Cycling Project Killorglin. Resource On-going in-house efforts to reduce consumption of office Efficienc consumables, energy efficiency in public buildings, reduction in y water consumption: Climate Change Action Plans. Participation in EWWR (See more detail further down)
Table 4.11: 2010 LAPN Programme - Food Waste Prevention Details
Locat Work Carried Out ion Regio Two workshops held for staff engaged in producing food. Target
Page 38 nal audience: restaurants, hoteliers, canteens, catering companies, culinary students, HSE personnel. Workshops held in Thomond Park (21/09/10) & Tralee IT (23/09/10). Leaflet produced & distributed.
Table 4.12: 2010 LAPN Programme - Networks for Waste Prevention
Locati Work carried Out on Dingle Lighting & energy workshop held on 15/10/10. Waste audit of Pobail Scoil completed. Individual actions for various businesses completed. Signage produced to aid segregation & divert waste from landfill. Project partner attended Fostering Sustainable Behaviour Workshop Kilmall Launch of Green Town Kilmallock during EWWR, 23 businesses ock committed to participate. Development of Green Community dimension via residential group & secondary school.
Development of “brand” to establish recognition of the project.
2011
Table 4.13: 2011 LAPN Programme - Limerick City:
Location Work Carried Out Results Páirc Na Stadium Resource Efficiency project 40% reduction in NGael which commenced in February and was waste to landfill. completed by November 2011. The (Gaelic programme included: Grounds Reduced cleaning Limerick) 4 waste audits to gather data & times for stadium give direction on prevention & segregation – recommendations all staff & volunteers implemented. 1 energy audit – recommendations now being implemented Greater awareness of source 1 water audit – recommendations segregation by
Page 39 now being implemented stadium spectator
Brown 1 energy audit – recommendations €47,000 savings Thomas under consideration by identified management Department Store Water audit conducted July – report & recommendations to be Potential to prevent submitted 241 tonnes of carbon emissions Waste audit which was deferred to January 2012 due to pre-Christmas trading issues.
Table 4.14: 2011 LAPN Programme - Limerick County:
Location Work Carried Out Results Kilmalloc A network of 18 businesses across a broad Cost savings in k Green spectrum has committed to actively energy waste & Town participate in this network. Data gathering is water produced Initiative now complete, 5 waste audits and 19 energy for each audits have been conducted. Detailed reports participating were prepared for each participating business business which includes metrics and recommendations for energy conservation and waste 2 workshops prevention. A workshop to present the delivered collective findings was conducted on October Small resource th 19 2011. A proposal is being investigated to grant provided by determine the feasibility of collective Community & tendering for energy for the town is underway Enterprise to which includes proposals to drive supply of pump prime renewable energy as part of the sustainable resource energy community initiative. efficiency work.
Table 4.15: 2011 LAPN Programme - Clare County:
Page 40 Location Work Carried Out Results
Carrigoran Follow up Ten Point Environmental Significant cost Nursing Improvement Programme (EIP) submitted savings achieved by Home to facility for consideration in December the Nursing Home 2011. Further assistance also provided to for waste the facility during tender process for waste management in services. second half of 2011 Staff Training completed for 40 staff but are commercially sensitive.
Greater awareness amongst staff of opportunities to prevent waste reported by the Homes Management Ennis and This project commenced in September Shannon 2011 and is modeled on the Cork County Leisure LAPN project. The Clare based leisure Centre’s: centre’s have swimming pools as well as dry side facilities. The project commenced with walk through observational audits, meetings with centre managers and the collection of baseline data for waste creation, energy and water consumption. Some energy auditing of the Shannon facility has already been undertaken and detailed audits are now planned for both facilities for January 2012. As part of the programme it is hoped to include an emphasis on awareness raising of waste prevention as part of the initiative.
Table 4.16: 2011 LAPN Programme - Kerry County:
Location Work Carried Out Results Dingle Resource Efficiency Programme for Local 26 businesses Peninsula Businesses: Corca Dhuibhne Glas awarded
Page 41 October 2011 Dingle Year one of assisting the festival to adopt a Food resource efficiency programme and reduce the Festival impact of the festival on the local environment
Table 4.17: 2011 LAPN Programme - Additional Projects:
Location Work Carried Out Results Greening of Distribution of Guides 2,000 guides distributed Festivals & Events Attendance at AOIFE 350 delegates attended Conference conference EWWR Eco-Pledge & Waste 130 people attended the Prevention workshop workshop
Over 1,000 pledges have been made
2012
Table 4.18: 2012 LAPN Programme - Current Projects:
Page 42 Locati Work Carried Out Results to June 2012 on Limeric Project to determine Two surveys conducted, identified need to k City attitudes to the use of promote alternative cleaning & DIY Council products that become products that are less harmful to the household hazardous environment. The survey identified the waste at their end of need to undertake a campaign to life. encourage householders to bin rather than flush certain wastes. Limeric 1. Greening of the Established a strong partnership with West k Limerick Show; Limerick Resources to develop Upcycling County pilot course to promote longer life and Council 2. Establishment of a reuse of furniture. If course is successful it pilot furniture will be expanded in 2013. Upcycling course to promote reuse Clare The study and report County phases of the Ennis A series of recommendations on resource Council and Shannon LCs efficiency have been established for each resource efficiency centre. The resource efficiency programme programme have been study has found that both centers are completed and reports already adopting many good circulated to the RWMO environmental practices, but that there is and EPA. scope to bring about improved environmental performance with regard to the consumption of energy and water and waste prevention and management. A budget of €3500 has been set aside to help both centers implement some of the low cost recommendations within these reports before year end.
Kerry 1. Greening of the Rose Assistance to the organising committee of County of Tralee Festival the Rose of Tralee Festival in benchmarking Council the waste generation, water and energy 2. Tarbert Household consumption for the 2012 festival. Waste prevention Research project
Two household surveys undertaken as well as bin weights and visual auditing to establish attitudes and barriers to waste
Page 43 prevention at household level.
Recent Legislative Requirements
The EC (Waste Directive) Regulations, 2011 indicate in general the direction that prevention should take and states the requirement to integrate the waste prevention programmes into future waste management plans.
In relation to waste prevention programmes Regulation 13 states the following
The Act of 1996 is amended by inserting the following section after section 27
Waste Prevention Programmes.
27A (1) The agency shall establish waste prevention programmes not later than 12th December 2013 in accordance with-
(a)Article 1 of the Waste Directive (to lay down measures to protect the environment and human health by preventing or reducing the adverse impacts of the generation and management of waste and by reducing overall impacts of resource use and improving the efficiency of such use), and
(b)the waste hierarchy set out in section 21A
2(a) The programmes referred to in subsection (1) shall be integrated into the waste management plans provided for in section 22 or into other environmental policy programmes as appropriate, or shall function as separate programmes.
(b) Where such programmes are integrated into waste management plan or into other programmes, the waste prevention measures shall be clearly identified.
The EC (Waste Directive) Regulations, 2011also gives examples of waste prevention ideas for integrating programmes into plans and the most relevant examples for household waste are given in Regulation 24 First Schedule No.’s 11, 12 and 13 as follows
“11. Economic instruments such as incentives for clean purchases or institution of an obligatory payment by consumer for a given article or element of packaging that would otherwise be provided free of charge.
12. The use of awareness campaigns and information provision directed at the general public or specific set of consumers
Page 44 13. The promotion of creditable eco-labels”
The prevention requirements of the EC (Waste Directive) Regulations, 2011are significant and the Local Authorities will have role in embedding prevention in the community so that behavioural change of individuals can be measured.
The “Roadmap to Resource Efficient Europe”, 2011 communication details the EU thinking on waste and suggests that waste should always be considered as a resource and also states that there should be an end to residual waste. “Review existing prevention, re-use, recycling, recovery and landfill diversion targets to move toward an economy based on re-use and recycling, with residual waste close to zero (in 2014); “
The recent Waste Management Policy (July 2012) also highlights the requirement for Local Authorities to prioritise waste prevention.
Environmental Considerations
Climate change is now considered to be one of the greatest threats to society both in an economic and from a safety and public health point of view. Avoidance of emissions from dealing with waste disposal is a key consideration in climate change and waste prevention is the highest and most desirable point of the hierarchy and is linked with resource efficiency. 48% of waste in the Region is sent for disposal (2010 figures) the bottom of the waste hierarchy and currently the only outlet for this is landfill. Landfill can contribute to global warming by releasing of methane gas to minimise this impact locally the landfills in the Region have installed facilities to collect and use some of the generated methane. Low levels of participation in waste prevention may contribute to increased waste generation that leads to increased carbon emissions from transport of waste and increased methane emissions from landfill of the waste.
Recommendations
The evaluation indicates that waste prevention is being integrated into waste management practices but that there is need to continue with the programmes in place as well as establishing more programmes. Due consideration should be taken of the ideas suggested in the EC (Waste Directive) Regulations, 2011 regarding packaging, waste awareness and behavioural change programmes as well as the promotion of eco-labels.
Whilst the L/C/K Region has built capacity in terms of implementing waste prevention programmes the programme needs to continue in the next generation of plans. The policies currently in place need to be updated to
Page 45 account for the changing needs including the status of the waste hierarchy and the need for inclusion of solid waste prevention objectives in Regional waste plans
In the face of changing waste management Regions, it is important to ensure forums exists for Local Authority staff to network, share and discuss potential efficiencies. The task groups for enforcement and education & awareness are useful forums and should continue.
New social media should continue to be embraced by Local authorities in the Region
EAOs will continue to contribute to and promote national campaigns particularly the NWPP and any other relevant environment awareness programmes.
Establishing a network of business contacts has been the key to successful promotion of waste prevention and minimisation. Contacts established through seminars, as well as through visits to individual companies, have provided a sound mechanism for ongoing effective communication. Links with business networks facilitated reaching further significant numbers of businesses.
In order to maintain and build upon this network, it is recommended that the dedicated role of RIWMO continues, in order to further engage in such networking and awareness activities with the industrial and commercial sector. By their nature, business networks as they expand open up new and significant opportunities through key links with business networks and organisations, providing potential for a greater number of links beyond the particular contacts made, as well as opportunities for participation in and speaking at business network events.
The plan objective to engage with the NWPP and LAPD/N programmes has been met and exceeded. The provision of funding via the LAPD/N programme has ensured that a full time member of staff has been in place to co-ordinate prevention activities and raises the profile of prevention in this Region.
However it should be noted that the existing funding arrangements for the prevention officer are somewhat less than satisfactory. The initial funding period was for a three year programme which allowed scope for learning to deliver prevention initiatives in a meaningful and comprehensive manner. The move to an annual funding programme has caused bouts of uncertainty for programme delivery and some delays in progressing initiatives as the programme cannot roll seamlessly from one year to the next.
The evaluation of the plan therefore presents an opportunity to ensure a commitment to the delivery of ongoing prevention initiatives. The role of the prevention officer is key in delivering the prevention objectives of future plans
Page 46 and therefore needs to be considered for a permanent post within the re- configured Regional waste structure.
There is a clear need to have standard qualitative and quantitative benchmarks for waste prevention to monitor progress and under the EC (Waste Directive) Regulations, 2011the determination of these benchmarks is the responsibility of the EPA. We suggest that it would preferable that these benchmarks would be developed early 2013 to assist with revision of plans rather than when the National Waste Prevention Plan is due for publication on 12th December 2013.
Page 47 5.0 HOUSEHOLD WASTE MANAGEMENT
5.1 Waste Collection/Uncollected Waste
The policies regarding waste collection in the current plan combine the integrated waste management and waste hierarchy approach to the development of waste collection systems and the relevant policies are as follows:-.
Chapter 14.4.2 Waste Collection
Waste collection policy will be centred on the expansion of collection services to maximise coverage throughout the Region. Pay by Weight/Use shall be fully implemented throughout the Region
Chapter 15.4
The Local Authorities shall endeavour to determine the extent of uncollected waste in the Region and to eliminate ‘environmentally unfriendly practices’ relating to the collection and disposal of household waste.
Assessing Implementation
Collection Service Collection of household waste within the Region is primarily done by private operators with Killarney Town Council the remaining Local Authorty providing a collection service. Despite a small drop in the estimated number of households signed up to a formal waste collection service in the Region in 2007 compared to 2006 the numbers have increased slightly year-on- year between 2007 and 2010, with a very slight decrease in 2011 (0.6%) where an estimated 94,350 householders signed up in 2011 accounting for 58% of households within the Region (based on the 2011 census). Table 5.1 below shows the estimated number of households signed up to a service, in each Local Authority Area between 2006 and 2011.
Table 5.1 No of Households signed up to a service Households Limerick Limeric Clare Kerry Regio City k County County nal Council County Council Council Figure Council s
2006 Number of households 16,9 25,3 22,2 25,6 90,2 signed up to a service. 91 00 85 83 59
2007 Number of households 16,9 23,7 21,9 26,2 88,9 signed up to a service. 49 77 20 73 19
2008 Number of households 20,3 23,0 21,8 26,6 91,9
Page 48 signed up to a service. 77 69 35 82 63
2009 Number of households 18,6 25,3 23,2 27,3 94,5 signed up to a service. 07 65 37 14 23
2010 Number of households 19,5 23,4 23,1 28,7 94,9 signed up to a service. 86 63 14 58 21
2011 Number of households 17, 26,4 94,3 signed up to a service. 150 26,905 23,814 81 50
The percentage households signed up to a service is shown in Table 5.2 below with 42% of householders not signed up to a service in 2011.
Table 5.2 Percentage of Households signed up to a service Households % Limerick Limeric Clare Kerry Average City k County County Regional Council County Council Council Figure Council
2009 Results expressed as a *79% *52% 53% 49% 58% percentage
2010 Results expressed as a *84% *48% 53% 52% 59% percentage
2011 Results expressed as a *73% *55% 54% 48% 58% percentage
*On-going issues with collectors correctly identifying Limerick County & Limerick City Boundaries
Table 5.2 also indicates a lower participation rate in Local Authorities with rural areas, this may be due to householders in these areas bin sharing or driving to landfills/transfer stations or CAS particularly since the economic downturn. A waste collection survey carried out in the Region in 2006 indicated that 8% of households were bin sharing and up to 21% of households were driving to landfills/transfer stations or CAS. The survey also revealed that 8% of householders were possibly disposing of their waste illegally – mainly backyard burning/burying/fly tipping. This survey was one of the targets set out in the plan.
In recent times public Pay-to-Use Waste Compactor Units (PTUs) have been sited at a number of locations throughout the Region. These units are advertised as means of disposal of household residual waste only. The continued roll-out of these units in the Region may affect the percentage of householders signed up to a collection service as well as having a negative impact on the recycling rate
Page 49 within the Region as the units roll-out to-date only provided for the disposal of household residual waste. It should be noted that a number of the PTUs rolled out within this Region were subsequently removed following follow-up by the relevant Enforcement Sections.
User charges:
A direct policy on user charges was not included in the plan however with the exception of Killarney Town Council, all authorised household waste collectors within this Region have been issued a Waste Collection Permit (WCP) in accordance with the Waste Management (Collection Permit) Regulations 2007 and Waste Management (Collection Permit) Amendment Regulations 2008, since 2008. The WCPs have specific conditions in relation to the charging mechanism for household customers and the type of bins to be provided.
In relation to the charging mechanism for household customers the WCP has the following condition:
Household waste shall only be collected in accordance with a Pay by Use system from the date of grant of this permit. To comply with this requirement a Pay by Lift, Pay by Tag, Pay by Weight system is acceptable. Systems relying solely on a fixed charge based on bin size with no user charge at all are not acceptable. The system shall provide a clear explanation of the calculation of the waste charge and shall provide an incentive for the customer to minimize residual waste. The permit holder shall forward a breakdown of the waste charge to the customer with the invoice or prior to renewal of contract and in any event at intervals not greater than six-month. This breakdown must identify in particular the proportional element of the charge and in cases where Pay by Weight is being used the weight per lift shall be included. In cases of Pay by Lift or Pay by Tag systems, the record of the number of lifts shall be included. All other charges should also be clearly identified on the invoice. Details of the requirement for a Pay by Use system shall be submitted in writing for confirmation of compliance with this permit to the nominated authority within 6 weeks of the grant of this permit
Therefore since 2008 all authorised household waste collectors within this Region have provided information on their charging mechanism to the RWMO. Where existing operators fail to comply with the above requirement the relevant Local Authority enforces the condition. New entrants are prevented from
Page 50 commencing operating until the RWMO and relevant Local Authorities are satisfied that the charging mechanism complies with the above requirement. If a Local Authority or RWMO become aware of a collector’s failure to comply with the above condition follow-up action is taken.
The following are examples of typical charging mechanism used by household waste collectors within this Region:
- The customer is charged a standard 6 monthly service fee & subsequently charged per lift each time the bin is emptied. The charge per bin depends on the type of bin i.e. the residual bin incurs the highest charge.
- The customer is charged according to weight of their residual bin i.e. different lift bands (assessed on the customers previous billing period) OR actual weight of residual bin (price/kg) OR a specific weight allowance with excess weight charged per kg. Dry recyclable and organic bins are collected for free.
- The customer is charged a standard 6 monthly fee which includes a number of tags which are placed on the residual bin each time it is presented for collection. Un-used tags can be redeemed as part of the next 6 monthly fee. Dry recyclable and organic bins are collected for free.
However it should be noted that in recent times the pay-by-use condition has proven very difficult to enforce as the high level of competition between collectors does not encourage compliance with this condition.
Uncollected Waste
The EPA, in the EPA National Waste Report 2010, revised their methodology for the estimation of uncollected household waste – the methodology used allowed for a 2% bin-sharing at occupied houses, home-composting of waste and the conventional ‘bin-type’ household waste brought to bring banks, CAS (other than glass, bulky waste, some wood, C&D waste and WEEE) as well as that brought to landfills (including fly-tipped) and this figure was then subtracted from the amount of waste generated by households and not collected at kerbside.
Based on the above assumptions & the 2011 census statistics the estimated uncollected household waste for Local Authority Areas within this Region are detailed in the Table 5.3 below:
Table 5.3 Tonnage of uncollected waste: 2010 - Estimated 2009 - Estimated Tonnes of Tonnes of LA Area uncollected waste uncollected waste Limerick City 2,455 3,361
Page 51 Limerick County 14,614 14,460 Clare 11,473 7,966 Kerry 12,879 9,056 TOTAL 41,421 34,843
41,421 tonnes of estimated uncollected waste for the Region in 2010 is equivalent to approximately 3.94M black bags of waste & represents almost 1/3 of household waste generated in this Region which is a significant issue for the Region particularly as there appears to have been a 19% increase in uncollected waste for the Region compared to 2009.
Limerick City is the only Local Authority within the Region where uncollected waste has decreased in 2010 compared to 2009 and this can be attributed to a 5% increase in the number of householders signed up to a collection service. The significant increase in the quantity of uncollected waste in Co. Clare & Co. Kerry in 2010 compared to 2009 is related to a significant decrease in the quantity of household waste brought to bottle banks, CAS and directly to landfill.
Table 5.4 below indicates the total number of environmental related complaints and the number of those which relate to litter which is estimated to be approx. 60% some of which may be related to the high level on uncollected waste.:-
Table 5.4 Total Complaints and Litter Complaints in the Region TOTAL TOTAL TOTAL ITEM 2008 2009 2010 Total Complaints investigated 5,471 7,505 6,127 Litter Complaints investigated 3,905 4,764 3,733 Dumping Line Complaints investigated 8 19 20
Recent Legislative Requirements:
Householders within the Region are regulated by Waste Presentation Bye-Laws:
- Limerick County Council Bye-Laws for the Presentation, Storage and Segregation for the purpose of and in the course of the Collection of Household and Commercial Waste 2011
Page 52 - County of Clare (Presentation and Collection of Household Waste and Commercial Waste), Bye Laws, 2007
- Kerry County Council (Presentation of Household Waste and Commercial Waste for Collection) Bye-Laws 2005
- Limerick City Council (Presentation and Collection of Household Waste and Commercial Waste) Bye-Laws 2005
The above Waste Presentation Bye-Laws require householders to present their household waste to an authorised service provider in a wheeled bin and to segregate their waste correctly according to the bins provided.
In addition to the above requirements the Bye-Laws implemented in Limerick County Council in January 2012 make it mandatory for a householder to sign up to a collection service, when provided which is hoped will increase the percentage of households currently on a collection service. It is envisaged that these Bye-Laws will be further rolled out in the Region in 2013 by Kerry, Clare and Limerick City. The recent Waste Management Policy (July 2012) has indicated that Regulations shall be published obliging householders to avail of an authorised waste collection service or be in a position to demonstrate that they are managing their waste in an environmentally appropriate manner, such as through the use of CAS.
It is hoped that the implementation of the Waste Management (Prohibition of Waste Disposal by Burning) Regulations 2009 will address the issue of backyard burning of household waste.
The legislative requirements and targets regarding collection in Regulation 31 of the EC (Waste Directive) Regulations 2011 are significant and place requirements on the Local Authorities to extend collection coverage as a whole and may also require a significant change in current collection practices. The viability of serving all householders, including rural households, needs to be considered and alternative solutions (technically, environmentally and economically suitable) for collection to these communities may need to be developed.
With the exception of Killarney Town Council, all authorised household waste collectors within this Region have been issued a WCP in accordance with the Waste Management (Collection Permit) Regulations 2007 and Waste Management (Collection Permit) Amendment Regulations 2008, since 2008. The WCPs have specific conditions in relation to the charging mechanism for household customers and the type of bins to be provided.
The recent Waste Management Policy (July 2012) for Ireland requires collectors to clarify charging structures including preparation of customer charters.
Page 53 In December 2011the L/C/K Region prepared guidance notes for applicants of Certificates of Registration (CoR’s) for the operation of public PTUs within the Region. These guidance notes detailed specific requirements in relation to the sitting and minimum acceptable design criteria for the unit i.e. the units as a minimum must have separate reception points and separate storage elements for the disposal of dry recyclable (blue bin) waste and residual (black bin) waste. To-date no PTU meeting the above requirements has been authorised within this Region.
Environmental Considerations:
The low levels of collection service, particularly in Co. Limerick, Co. Clare & Co. Kerry, has the potential to lead to increasing levels of illegal dumping and or backyard burning, as indicated in the 2006 Regional survey. From an environmental perspective, illegal dumping has possible implications for biodiversity, surface water and groundwater depending on where the dumping occurs. Similarly emissions from backyard burning have implications for air quality, climate, biodiversity and human health. The continued roll out of PTUs which only accept residual household waste will have a direct impact on the recycling rate within the Region resulting in an increased quantity of waste requiring disposal which has subsequent negative environmental impacts.
Recommendation:
Although the number of householders signed up to a formal waste collection service in the Region has generally been increasing year on year since 2007 and the Regional recycling rate for householders exceeds 42% there are still over 40% of households within the Region not signed up to a waste collection service..
In order to identify appropriate measures (awareness and/or enforcement) to reduce the percentage of uncollected waste and associated illegal dumping within the Region the survey carried out in 2006 needs to updated in order to obtain a current, accurate picture of what is happening on the ground.
The methodology used to calculate the amount of uncollected waste within the Region needs to take account of the EPA’s proposed amended methodology which includes new developments such as the increasing practice of PTUs, as well as better estimates of bin sharing arrangements – this information shall be important in relation to obtaining a more accurate calculation of uncollected waste within the Region and implementation of measures to reduce the quantity of uncollected waste
It would also be extremely beneficial to have a statistically valid survey of household waste management behaviours (e.g. use of kerbside collection services versus bring centres, home composting information etc.), to assist in the implementation and evaluation of national waste policy. To this end, the EPA
Page 54 has submitted a proposal to the Central Statistics Office (CSO) for the inclusion of a household waste module in the Quarterly National Household Survey and in due course findings from this should be considered when assessing targets.
It is also recommended that the future key policy objectives need to be included for household waste collection and segregation and these need to be more specific and measurable to reflect recent legislative changes in the area and should include a KPI for number of households signed up to a service. As the current pay-by-use WCP condition has proven very difficult to enforce, consideration should be given to a move away from a pay by use system towards a specific pay by weight system to counteract the ‘Flat Charge’ type marketing. Due to the recent roll-out of privately operated PTU’s within the Region the role of these units, along with a clear policy on their use, needs to be included in any revised/replaced plan.
5.2 Re-use and Recycling The recycling policy in the plan was based on continued roll out of kerbside collection of mixed dry recyclables and targets were set for increasing the number of recycling centres/CAS as well as Bring Banks.
Chapter 14.4.3 Waste Reuse & Recycling
The policy shall focus on encouraging and regulating householders and the private sector to maximise reuse & recycling in the Region
Chapter 15.3.1 Reuse and Recycling Household and Community
Local Authorities shall promote reuse and recycling at all levels to achieve Regional targets in conjunction with the EU hierarchy. Local Authorities will continue to promote the kerbside collection of dry recyclables
Assessing Implementation
In the Region many campaigns to promote recycling were carried out over the past six years starting with a leaflet that was distributed at recycling centres to an estimated 20,000 persons, the leaflet explained about levels of recycling and what happens each waste type after it leaves the household.
The household recycling rate has continued to increase since the 2006 plan was published and this is a KPI for this plan. The baseline figure was set at 13.9% based on the 2004 statistics. The household recycling rate has been measured annually; initially the Region was using a rate based on waste generated and in
Page 55 the latter years of the plan the recycling rate was based on waste managed only. The 2010 household recycling rate for this Region is 42% and is just ahead of the EPA national indicator figure is 41%. It also compares favourably with the rest of the Regions as shown in Fig. 5.1 below, with only Wicklow a single county and Dublin with a higher recycling rate.
Household Waste Recycling Rate (%)
0.6
0.55
0.5
0.45
0.4
0.35
0.3
0.25
0.2
Fig. 5.1 Regional Household Recycling Rate Comparison
A recycling campaign has been running in the Region over the last number of years and each year the campaign focused on one recyclable material as shown below:-
Page 56
This information was presented as advertisements in one local paper circulating in each functional area. These adverts have now also been published as posters for schools and will be distributed in Autumn 2012.
Based on the total weekly circulation rate of 103,296 for the Regional newspapers (i.e. Clare Champion, Kerryman, Limerick Leader and Limerick Post) within this Region (Refer to Table 4.2 above) and the established facts which indicate that Regional papers are read between 4 and 7 times as they are kept in people’s homes for at least 7 days or longer there was an opportunity to influence between 413,184 – 723,072 members of the public through each of the above advertisement campaigns.
One of the KPIs for recycling is the number of households with a segregated collection service. The baseline 2005 figure estimated that less than 10% of households had a dry recyclable kerbside collection, whereas the 2011 figures showed that 99% of households have a segregated dry recyclables collection. During 2005 -2007 the Local Authorities in the Region enforced the conditions of the WCPs with subsequent improvement in the number of households with a dry recyclable collection was achieved.
5.3 Organic Waste Collection
The policy on organic waste in the Region was based on the National Strategy on Biodegradable Waste published in 2006. Chapter 15.5 of the plan states:
The Local Authorities shall endeavour to meet the targets outlined the National Strategy on Biodegradable Waste.
Since September 2009 the permitted household waste collectors, within this Region, have had a target set out in their WCP conditions requiring the collection of segregated household organic waste, with the following target specified since December 2010.
Page 57 As a minimum 40% of households must have segregated organic collection in each Local Authority area. The charging system for organic waste shall incentivise households to participate in source segregation of organic waste. The frequency of collection must ensure the organic waste is suitable for further biological treatment.
The 3-bin system is being introduced slowly throughout the Region and this is working in tandem with new EPA restrictions on biodegradable household waste entering landfill. The 2011 returns show that 42% of serviced households, within the Region, are now provided with a segregated organic collection service, exceeding the December 2010 target of 40%.
As can be seen in Fig 5.2 below, the roll-out of the household organic bin has resulted in a significant increase in the quantity of household biodegradable waste collected within the Region since 2008.
Household source segregated biodegradable waste
4000 3500 3000 2500 Household biodegradable waste 2000 1500 1000 500 0 2008 2009 2010 2011
Fig. 5.2 Quantity of source segregated household biodegradable waste collected within the Region 2008-2011
Further enforcement exercises will continue to ensure that all household waste collectors comply with the minimum 40% target, specified in their WCP. Since the September 2009 WCP target requiring 20% of householders in each Local Authority area to be provided with a segregated organic collection the RWMO has been in regular contact with all authorised household waste collectors in relation to the implementation of the target. Mostly recently in May 2012 the RWMO wrote to all authorised household waste collectors who had failed, at the end of December 2011, to comply with the 40% target. The letter highlighted
Page 58 that the relevant Local Authority(s) maybe initiating legal action for failure to comply with the 40% target.
Many awareness campaigns were carried out to ensure that the segregated brown bin collection targets were achieved. The first advertisement shown below was published in one local newspaper circulating in each Local Authority area. This was followed later in the year by three bin ad which indicated again the material required to go into the three bins.
5.4 Bring Banks
The policy related to bring banks is included under Chapter 15.3 Reuse and Recycling and specific objectives relating to bring banks were set as follows:
Objectives:
Bring Banks will continue to be distributed throughout the Region
Local Authorities will continue to improve management and maintenance at bring bank facilities
Additional bring banks will be provided with a range of facilities to meet demand where it is practical and subject to availability of resources
Assessing Implementation
In June 2006 there were 215 bring banks within the Region and by December 2011 there were 231 bring banks in the Region (2011 NWR) which is the highest number of bring banks in the Region since the start of this plan.
Page 59 The tonnage of waste collected at bring banks has contributed significantly to the overall household recycling rate over the plan period and the tonnages collected are illustrated in Table 5.5 (Refer also to Figure 5.3 below).
Table 5.5 Tonnage of Waste Collected at Bring Banks in L/C/K Region 2006 - 2010
Waste Source 2006 2007 2008 2009 2010
Bring Banks 7,953 8,218 8,465 7,914 7,077 Tonnes
In the last two years there has been a slight decrease in the total tonnage collected at bring banks that may be related to the economic downturn and to increased roll out of the kerbside household mixed dry recyclable bin.
5.5 Recycling Centres/Civic Amenity Sites/Transfer Stations
The policy related to recycling centres is included under Chapter 15.3 Reuse and Recycling and specific objectives relating to recycling centres were set as follows:
Objectives:
Recycling Centres to accept a wider variety of materials.
To standardize reporting systems for all waste streams accepted at Recycling Centres.
Recycling centres have been described as CAS or in the case of Kerry they have been know as transfer stations. These sites have assisted the Local Authorities in reaching the recycling targets for the Region. The types of wastes accepted at these sites has expanded over the period of this plan. The charging mechanism varies throughout the Region and some centres accept residual waste.
The tonnage of waste collected at recycling centres has contributed significantly to the overall household recycling rate over the plan period and the tonnages collected are illustrated in Table 5.9.
Table 5.6 Tonnage of Waste Collected at Recycling Centres in L/C/K Region 2006 - 2010
Waste 2006 2007 2008 2009 2010 Source
Page 60 Recycling 10,82 13,41 16,55 10,14 10,709 Centres 5 6 2 7 Tonnes Note: The tonnages above exclude WEEE, residual waste and bulky waste delivered to Recycling Centres
The tonnages demonstrated graphically, in Figure 5.1 below, show a decline in waste delivered to bring bank and recycling facilities in line with economic growth.
20,000
15,000
10,000 Bring Banks Tonnes Recycling Centres Tonnes
5,000
0 2006 2007 2008 2009 2010
Fig. 5.3 Regional Recycling Rate Comparison
The EPA have introduced a standard reporting procedure for recycling centres/CAS and the Local Authorities in the Region have endeavoured to be consistent in their approach to generating these figures.
Legislative Update
From a household waste collection & recycling perspective key objectives of the EC (Waste Directive) Regulations 2011 are defined in Regulation 31 (c) which states: (c) Subject to section 29(2B) of the Act of 1996, by 2015 separate collection shall be set up for at least the following waste:
(i) paper;
(ii) metal;
(iii) plastic; and
(iv) glass
Page 61 (2) In order to comply with the objectives of the Waste Directive, and move towards a European recycling society with a high level of resource efficiency, and without prejudice to any other targets or obligations which may apply as a result of waste prevention and management legislation and policy, the Minister, the Agency and the Local Authorities shall, in carrying out their respective functions under the Act of 1996, take the necessary measures designed to achieve the following targets:
(a) by 2020, the preparing for re-use and the recycling of waste materials such as, at least, paper, metal, plastic and glass from households and possibly from other origins as far as these waste streams are similar to waste from households, shall be increased to a minimum of overall 50% by weight;
The above requirement for separate collection of dry recyclables by 2015, if implemented as stated, shall have a significant impact on the current collection practice of collecting mixed dry recyclables. It should also be noted that the requirement to collect segregated glass at the kerbside is currently optional for permitted collectors within this Region; however collection of glass at the kerbside will undoubtedly increase the recycling rate. Any changes to WCP requirements would require a review of relevant WCPs.
In relation to bio-waste segregation Regulation 38 of the EC (Waste Directive) Regulations 2011 states: The Minister shall take measures, as appropriate, and in accordance with sections 21A and 32(1) of the Act of 1996 and Regulation 32, to encourage—
(a) the separate collection of bio-waste with a view to the composting and digestion of bio-waste,
(b) the treatment of bio-waste in a way that fulfils a high level of environmental protection, and
(c) the use of environmentally safe materials produced from bio-waste.
With the recent Waste Management Policy (July 2012) for Ireland requiring:
“Separate collection of organics will be a required waste permit condition for those collecting from households within population centres of a given size and will be introduced on a phased basis over a 4 year period beginning with larger population centres.”
The policy indicated that relevant Regulations would be published in September 2012.
In 2009 the EPA published the Technical Guidance Document – ‘Municipal Solid Waste - Pre-treatment & Residuals Management’ which set out the EPA’s standard for minimum acceptable pre-treatment for Municipal Solid Waste
Page 62 accepted for landfilling or incineration at EPA licensed waste facilities. The guidance requires operators of landfills and incineration facilities to demonstrate via their waste acceptance policy (as established by licence conditions) that waste accepted at these facilities has been subjected to appropriate pre- treatment which is going to be challenging as we approach the 2013 BMW target.
With the exception of Killarney Town Council, all authorised household waste collectors within this Region have been issued a WCP in accordance with the Waste Management (Collection Permit) Regulations 2007 and Waste Management (Collection Permit) Amendment Regulations 2008, since 2008. These WCPs have specific conditions in relation to the charging mechanism for household customers and the type of bins to be provided.
The recent Waste Management Policy (July 2012) states that it is going to strengthen the regime regarding household waste collection with many proposals outlined in Section 4.3.1 of the recent Waste Management Policy in Ireland.
Environmental Considerations
Failure to maximize the re-use and recycling rates shall result in increased quantity of waste requiring disposal most likely at landfill within this Region, the capacity of which is reducing significantly year-on-year. Notwithstanding the pollution control activities at landfill facilities and the governing conditions set down in the Waste Licences, the landfilling of mixed waste results in environmental nuisances such as leachate, landfill gas and odour generation. Any waste not segregated for recycling that ends up in landfill is also wasting resources that could be used as raw material for producing another product rather than using virgin material and in some cases the material could be used in generation of renewable fuels to supplement and/or replace fossil fuels.
The landfill directive requires the reduction of biodegradable municipal waste in the body of the landfill as organic waste is a major contributor to landfill gas generation during degradation. Landfill gas contains both methane and carbon dioxide, both of which contribute to global warming. So the effect of non- segregation of organic waste generally means that this waste will be consigned to landfill resulting in additional global warming impacts.
Recommendation
As the household recycling rate now is close to the overall recycling target set out in the plan, there is an opportunity to increase the targets in the plan which will also fulfill the requirement of the EC (Waste Directive) Regulations 2011 of a recycling rate of 50% by 2020. High quality recycling must be reached at the separation plants and the licensing/permitting authority will be responsible for
Page 63 ensuring best practice at these types of facilities. New objectives need to be developed that maintain the current high recycling rate in the L/C/K Region.
A quantity of the segregated organic waste collected at kerbside is currently being stabilised then used in landfill to reduce the BMW fraction. This is not a sustainable approach and markets for the product need to be developed or risk undermining public confidence. It is also apparent that there continues to be high levels of contamination in the segregated organic waste stream that limits the end use options for this material. Therefore a clear policy on organic waste collection and disposal should be included in any revision of the plan in line with the recent Waste Management Policy (July 2012) and any future associated Regulations. Future key policy objectives for organic waste need to be more specific, measurable and reflect recent legislative changes in the area particularly in relation to specifying targets for home composting and percentage yield of biowaste arisings. They also need to focus on the need for further/continuing education of householders to improve the quality of brown bin waste presented for collection.
It would also be extremely beneficial to have a statistically valid survey of household waste management behaviours (e.g. use of kerbside collection services versus transfer station, bring centres PTUs and home composting) to assist in the implementation and evaluation of national waste policy. In order for the household charging mechanism to be an effective tool in increasing recycling rates all Regions need to ensure the relevant WCP conditions, for household collectors, are enforced as a number of household collectors operate across a number of Regions.
Page 64 6.0 COMMERCIAL WASTE MANAGEMENT Commercial waste is described in the national waste reports as a term to describe the non-household fraction of municipal waste, which is produced by commercial premises such as shops, offices and restaurants, as well as municipal premises such as schools, hospitals etc. It also includes non-process industrial waste arisings from factory canteens and offices.
Chapter15.3.3 of the plan refers to Commercial Waste
Policy The Local Authorities will assist in raising awareness of the reuse and recycling opportunities in the industrial and commercial sector in order to reach Regional targets.
Objectives -Local Authorities shall facilitate workshops to identify opportunities to reuse waste streams produced at industry/ business level and promote successful case studies appropriately. -Local Authorities will support initiatives by SMEs to set up reuse / repair schemes and waste clubs.
Target to 2010:
At least 2 reuse / recycling workshops per year to be held by each Local Authority for the industry and business sector.
For initiatives on reuse in the industry and business sector, please refer to Chapter 4.4 of this evaluation.
In 2011 the Region published the “Waste Legislation for Retailers” booklet to provide a concise source of the key points of different relevant regulations.
6.1 Commercial and Industrial Waste Generation and Recycling
Assessing Implementation
Page 65 Measuring commercial waste has been refined over the years of the plan and better procedures for auditing and verification of data has also been achieved. The Region had been measuring commercial and industrial waste arisings together and this certainly followed the trends in economic growth over the life of this plan but seem to have stabilized in the latter years as can be seen from Fig 6.1 below.
Tonnage of C & I Waste
250,000 200,000 150,000 Tonnage 100,000 50,000 0 20062007200820092010
Fig. 6.1 Commercial and Industrial waste arisings per annum
In 2010 and 2011 the Region measured commercial waste based on the European Waste Code (EWC) categories agreed with the EPA to allow for comparisons between Regions. Commercial and Industrial Wastes have now been subdivided into a number of categories.
There are two key performance indicators for the Commercial and Industrial Waste in the Plan and they are the following:-
1. Commercial and Industrial Waste generated per employee
2. Commercial and Industrial Recycling Rate
The waste generated per employee is based on an extrapolated employment rate for the Region estimated from CSO quarterly returns on numbers of persons employed.
Waste generated/Employee kgs
1200 Waste 1100 generated/Employ 1000 ee kgs 900 800 2006 2007 2008 2009 2010
Page 66 Fig. 6.2 Commercial and Industrial waste arisings per Employee
The trend shows a major decline in waste generation which reflects the fall in economic growth between 2006-2008. In more recent years the rate has stabilized. An opportunity is now presented to decouple economic growth from waste generation before the next growth phase.
The commercial and industrial recycling rate has been influenced by the packaging regulations which successfully encouraged waste packaging to be recycled. The recycling rate shows little variance over the last number of years as shown below in Fig 6.3 below and this is in line with national rate.
C & I Recycying rate %
1 C & I Recycying 0.5 rate %
0 2006 2007 2008 2009 2010
Fig. 6.3 Commercial and industrial waste percentage recycling
6.2 Commercial Organic Waste The policy regarding commercial organic waste collection is specified in Chapter 15.5 of the plan and includes stringent objectives and ambitious targets
Policy:
The Local Authorities shall endeavour to meet the targets outlined in the National Strategy on Biodegradable Waste.
Objective:
Separate Organic waste collection service to be provided to all appropriate commercial and industrial premises
Targets to 2010:
To divert 35% of organic waste from landfill as set out in the National Biowaste Strategy: -Minimum of 60% coverage for separate collection and biological treatment of food waste from commerce at an average yield of 60%.
Page 67 Roll out of organic waste collection service to all commercial and industrial premises during 2006 in accordance with waste collection permits, with completion by 2009.
In relation to the collection of commercial organic waste the following condition is specified in the WCP issued to authorised collectors:
A separate system for kerbside collection of organic waste from commercial and industrial premises shall be commenced by 1st January 2009 and be implemented by 2010 in accordance with the attached schedule Table 2. Details of compliance with the requirements of Table 2 of the Schedule shall be submitted in writing at the request of Limerick County Council. Table 2: Date: Target
1st January 2009: 50% Diversion of Commercial Organic Waste from Landfill 1st January 2010: 100% Diversion of Commercial Organic Waste from Landfill
OR for more recently issued WCPs the following condition is specified:
Where residual waste is collected in the Limerick/Clare/Kerry Region, a separate system for kerbside collection of organic waste shall be provided to all producers, as defined in the Waste Management (Food Waste) Regulations 2009 and any subsequent amendments. The charging system for organic waste collection shall incentivise businesses to participate in source segregation of organic waste.
The Region has had a continued awareness programme in place since 2007 and had held events for waste producers and waste collectors to ensure that a clear understanding could be established of the requirements of the plan and the new legislation concerning commercial food waste segregation.
Newspaper advertisements were prepared and leaflets were distributed widely.
Page 68 Since 2008 there has been a significant increase year-on-year on the total quantity of commercial biodegradable waste collected for recovery within the Region with the largest increase between 2010 and 2011 (i.e. 43% increase) indicating the effectiveness of the sustained enforcement and awareness programmes implemented in 2011. Table 6.1 & Fig 6.4 below shows the rise in tonnage of source segregated organic commercial waste collected since the programme got underway in 2008.
Table 6.1 Tonnes of Source Segregated Commercial Organic Waste collected in the Region since 2008 200 200 201 201 8 9 0 1 Commercial biodegradable waste collected for 817 1,48 3,11 4,83 recovery (tonnes) 8 2 5
Commercial biodegradable waste
6000 5000 4000 Commercial biodegradable waste 3000 2000 1000 0 2008 2009 2010 2011
Fig 6.4 Commercial Organic Waste collected within the Region 2008- 2011
In order to ensure compliance with the above targets the Local Authorities within the Region and the RWMO have taken the following enforcement measures:-
In February 2011 & February 2012 the RWMO wrote to all authorised commercial waste collectors involved in the collection of organic waste within the Region requesting information in accordance with Article (9)(4) of the Waste Management (Food Waste) Regulations 2009. The above Article states ‘An authorised waste collector shall, on an annual basis, and by 31December in each calendar year, inform the relevant Local Authority of persons who are refusing to avail of the source segregated waste collection service.’. Information provided is then used by the Local
Page 69 Authorities within the Region to target inspections under the Regulations – premises listed in responses received are not specifically targeted.
In 2011 commercial sector compliance with the Waste Management (Food Waste) Regulations 2009 was targeted on a town basis with all relevant waste food producing premises inspected with subsequent follow up as required. To-date towns such as Newcastle-West, Abbeyfeale, Adare, Dingle, Limerick City centre and Environs have been targeted. Clare County Council has generally targeted their inspections based on specific sectors i.e. hotels & supermarkets. To-date premises are generally complying with the Regulations when follow-up inspections are carried out. For more recent targeted inspections relevant premises are written to prior to inspections to inform them of the Regulations, provide them with information packs and of the up-coming inspection – this has resulted in a much higher compliance rate at initial inspections and reduces the number of re-inspections required. As a follow-up to inspections relevant collectors are written to where they have not provided premises with the required food bin.
Recent Legislative Changes
S.I no 798/2007 –Waste Management (Packaging) Regulations 2007 were issued after the publication of the plan. These Regulations replaced the previous Regulations and intend to assist in reaching the EU recycling targets as follows:- (a) a minimum of 60% of packaging waste by weight is recovered; and
(b) a minimum of 55% of packaging waste by weight is recycled in total, including material specific recycling targets
- 60% by weight for glass
- 60% by weight for paper and board
- 50% by weight for metals
- 22.5% by weight for plastics, and
- 15% by weight for wood
The most significant change in legislative requirements with regard to organic waste was the publication of the Waste Management (Food Waste) Regulations 2009 which came into effect in July 2010. The Regulations mean that producers of food waste must 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
Page 70 recycled in a food waste recycling plant (e.g. composting plant). 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.
Environmental Considerations:
Segregated recyclables are generally reprocessed prior to reuse and segregated organic waste is composted or digested resulting in the production of compost or energy. Both options use the waste as a resource with less environmental impact than landfill.
Failure to maximise the segregation of commercial recyclables and organic waste at source shall result in increased quantity of waste requiring disposal most likely at landfill within this Region, the capacity of which is reducing significantly year-on-year. Notwithstanding the pollution control activities at landfill facilities and the governing conditions set down in the Waste Licences, the landfilling of organic waste results in environmental nuisances such as leachate, landfill gas and odour generation. It should be noted that the disposal of organic waste in landfill produces significant quantities of landfill gas as a result of the anaerobic decomposition of the organic materials. Landfill gas can contain up to 65% methane by volume. Methane (CH4) is a greenhouse gas with a global warming potential twenty-one times that of carbon dioxide (CO 2). Landfill gas management infrastructure requires significant investment.
Recommendation
Waste composition studies carried out on behalf of the EPA reveal the residual commercial waste still contains high level of materials for recycling and recovery. Investigations in the Regions show that commercial premises are quite good to separate glass, cardboard and paper but other recyclables are often mixed with residual waste and collectors were not facilitating this mixed recycling collection for business either, as required under their WCP. It is recommended that a policy be introduced to ensure that collectors provide mixed recycling bin to all commercial premises and that these bins are used appropriately by the premises through the enforcement of existing legislation.
In addition to the above the enforcement of existing legislation in relation to the segregation and separate collection of food waste is key i.e. Waste Management (Food Waste) Regulations 2009, WCP conditions and specific Local Authority Waste Presentation Bye-Laws. Enforcement activities need to target both the authorized collectors, to ensure they are providing the required segregated organic waste collection service, and the commercial sector i.e. via specific urban centres and/or specific sectors, to ensure proper segregation of food waste at source. The current policies need to be amended to reflect this.
Page 71 It is also recommended that the future key policy objectives for organic waste are more specific, measurable and reflect recent legislative changes in the area particularly in relation to specifying percentage yield of biowaste arisings. They also need to focus on the need for further/continuing education of customers to improve the quality of brown bin waste presented for collection.
The continuing requirement for commercial premises to source segregate a number of waste types has led to issues in relation to insufficient waste storage capacity particularly in city/town centre commercial areas. This issue needs to be addressed via Local Authority Development Plans and Local Area Plans. Although there is currently no Irish national guidance document in relation to storage capacity requirements cognisance should be given to the Northern Ireland guidance document ‘Local Government Waste Storage Guide for Northern Ireland.’
7.0 MUNICIPAL WASTE INCLUDING BIODEGRADABLE MUNICIPAL WASTE. Municipal solid waste is described in the National Waste Reports as household waste as well as commercial waste and other waste that, because of its nature or composition, is similar to household waste. It excludes municipal sludges and effluents. In the context of this evaluation municipal waste consists of three main elements households, commercial (including non-process industrial waste), and street cleansing waste (street sweepings, street bins and municipal parks and cemeteries maintenance waste, litter campaign material).
The plan did not specifically set municipal waste policies but rather dealt with independent components making up municipal waste. In recent years the method of calculation of municipal waste has been refined and therefore we can only look at trends over the last two years of both municipal waste managed and generated (generated includes uncollected waste).
Table 7.1 Municipal Waste Generated Regional Regional Total 2009 Total Waste Source 2010
Total Quantity of Household, Street 353,385 356,147 Sweepings and Commercial/industrial Waste Generated
Total Quantity of Household, Street 303,636 313,052 Sweepings and Commercial/industrial
Page 72 Waste Managed
The municipal waste recycling rate has also been monitored over the last few years and remains in the range of 49-52%
7.1 Biodegradable Municipal Waste The policy relating to biodegradable municipal waste is outlined in Chapter 15.5.1
Policy:
To reduce the quantity of biodegradable waste landfilled in accordance with the EU Landfill Directive. An integrated approach to waste management will require treatment technologies such as Mechanical Biological Treatment (MBT) in order to reach the 2010 and 2013 landfill diversion target and to meet the 2010 target set out in the National Biowaste Strategy.
Objectives
-To achieve the 2010 target as set out in the National Biowaste Strategy through a combination of source separated collection and appropriate treatment, combined with collections with other waste streams, with appropriate Mechanical Biological Treatment, home composting and green waste recycling centres. -To facilitate the development of Biological Treatment in the Region -To investigate the use of end products from biological treatment (compost) by Local Authorities in horticultural use and in restoration of landfills, in line with specific recommendations of the National Biowaste Strategy. -Local Authorities will encourage the development of green waste recycling centres by the private sector. -The Local Authority Awareness officers will facilitate and encourage the provision of small-scale central composting for communities, for example, at apartment complexes and shopping centres.
Targets to 2010: -The Local Authorities shall carry out a pilot study investigating the market potential of materials arising from biological treatment by the end of 2006 -Two additional biological treatment facilities shall be provided in the Region be the end of 2007
Page 73 Assessing Implementation
The details on source separation of Household and Commercial Waste are discussed in Chapters 5 and 6 of this report . Many proposals have been presented to the Region for additional biological treatment facilities but no major facility has been developed at this stage.
A market survey on the use of composted waste was carried out in 2006 and 2007 and this revealed that markets for products were available in the Region but a quality standard on composting was awaited at that time. In 2009 the EPA published the ‘Development of an Industry-Led Quality Standard for Source- Separated Biodegradable Material Derived Compost ‘.
Two additional green waste facilities were located in County Limerick and County Clare so the targets have been reached.
The more specific landfill diversion target is currently being monitored by the EPA and all landfill licences were reviewed and new targets were included to limit the BMW deposited in the body of the landfill. All landfills seem to have difficulty in reaching the 2013 and 2016 targets which require a 40% and 15% BMW limit respectively.
Environmental Considerations & Recommendations.
Refer to Chapter 5 & 6 for details
Page 74 8.0 CONSTRUCTION AND DEMOLITION WASTE MANAGEMENT. Construction and Demolition (C&D) waste is described in the National Waste Report as all waste that arises from construction and demolition activities (including excavated soil from contaminated sites). This was a significant stream in 2004 but grew at a rate greater than our economic growth rate during the first year of the plan to reach over 1m tonnes per annum.
The policy, objectives and targets relating to C&D waste in the plan are included in Chapter 16.1
Policy:
To reduce the generation of C&D waste and ensure that reuse and recycling of this waste is maximised in support of the Implementation Plan for the Management of C&D Waste in the Region.
Objectives:
Local Authorities shall encourage compliance with the Implementation Plan for the Management of C&D Waste
To promote the most sustainable reuse of C&D waste
Local Authorities will promote and raise awareness of the recycled materials that are available for construction, where available, and promote successful developments that have used recycled materials, to support and promote the ongoing producer responsibility initiatives within the construction industry
To ensure that a C&D Waste Plan is prepared by the developer for new construction or demolition projects above the threshold limits as set by the NCDWC and that the maximum amount of waste material generated on-site is re-used and recycled
To promote the production of aggregates from C&D waste and their use in construction projects in the Region
To ensure that appropriate Local Authority construction projects are assessed for the potential reuse of C&D waste
To actively enforce Waste Permits and Collection Permits with respect to C&D waste
Local Authorities will encourage the development of C&D recycling facilities at suitable sites, for example, quarries
Page 75 Local Authorities will support the objectives of the NCDWC voluntary initiative
Local Authorities will encourage the development of centralised facilities for the recycling of C&D waste will be encouraged. Targets to 2010:
To ensure the adequate provision adequate of C&D waste facilities in the Region in accordance with national targets
Local Authorities to engage with private sector in the development of C&D waste recycling facilities by 2007
Assessing Implementation
C&D waste arisings within the Region peaked at over 1.0 million tonnes in 2006 and showed a rapid decline in the preceding years. There has been a slight increase in the quanity of C&D waste arisings over the last 2 years, primarily due to the re-generation works in Limerick City.. Figure 8.1 below graphs the C&D waste arisings within the Region 2004-2011.
C&D Waste 2004- 2011
1,200,000
1,000,000
800,000 C&D Waste 600,000
400,000
200,000
0 2004 2005 2006 2007 2008 2009 2010 2011
Fig 8.1 C&D Waste arisings within the Region 2004-2011
Page 76 The decrease evident in the C&D waste stream is reflective of the economic downturn and its effect on the construction sector and is similar to the national trend of 81% reduction in C&D waste.
In relation to the C&D waste collected within the Region there are still difficulties in getting accurate recording of recovery and disposal in this sector, but from the verified returns the recycling rate has now surpassed the EU target of 85% to reach 99%. It is important to remember that the bulk of the waste is soil and stones i.e. accounted for 64% of C&D Waste generated within the Region in 2011
Waste Facility Permits (WFP) & Waste Collection Permits (WCP):
The decline in the level of activity in the construction sector has seen a corresponding reduction in the number of permitted land deposition sites and active C&D collectors within the Region since 2007.
The number of land deposition permitted sites, within the Region, has decreased significantly over the last number of years from a high of 170 sites in June 2007 to 69 sites in June 2010 to just 18 sites in December 2011. There are now only approximately 50 active C&D collectors in the Region down from a high of 200 in 2007.
The relevant Local Authorities within the Region enforce the WFPs & WCPs and have been actively enforcing those with respect to C&D waste over the lifetime of the plan particularly during the boom construction activity years. The Local Authorities within the Region also inspected a number of construction sites, over the lifetime of the plan, to ensure compliance with waste management legislation, adherence to best practice guidelines and to ensure the maximum amount of waste material is recycled/recovered.
C&D Waste Plan:
In July 2006 the DECLG published ‘Best Practice Guidelines for the Preparation of Waste Management Plans for Construction & Demolition Projects’ which was subsequently given statutory footing in 2007 under Section 28 of the Planning & Development Act 2000.
In relation to C&D Waste Plan:
(a) the Clare County Council County Development Plan 2011 – 2017 CDP 9.7 states: It is an objective of Clare County Council: (a) To require that a C&D Waste Management Plan is prepared by the developer having regard to the DoEHLG’s publication Best Practice Guidelines on the Preparation of Waste Management Plans for Construction and Demolition Projects for
Page 77 new construction or demolition projects and to require that the maximum amount of waste material generated on site is reused and recycled;
Clare County Council carried out significant work in this area during the lifetime of the Regional WMP. The environment and planning sections of the council liaised on this matter, with the result those developments above the National Construction and Demolition Waste Council (NCDWC) thresholds were requested to provide C&D waste management plans during the planning permission process. Such plans were assessed by the environment section and compliance with the plans was monitored over the duration of the relevant projects. Owing to the sharp fall-off in construction activity in recent years, there have only been a very small number of projects in the county that exceeded the NCDWC thresholds.
(b) The Limerick County Council County Development Plan 2010 to 2016 Objective IN O46 states: ‘It is the objective of the Council to ensure that all significant construction/demolition projects include construction and demolition waste management plans. These plans should seek to focus on waste minimisation in general and optimise waste prevention, re-use and recycling opportunities and are required for developments of five or more housing units or commercial or industrial developments on sites in excess of 0.5 hectares.’
The implementation/enforcement of C&D waste management plans in Limerick County Council has encountered a number of issues and the area needs to be addressed.
(c) The Limerick City Council County Development Plan 2010 to 2016 Policy EM.10 states: ‘It is the policy of Limerick City Council to require Applicant/Developer at the planning stage to address the issue of waste management for both the construction phase of the development and the operational phases.’
Depending on the size of the project Limerick City Council, via planning conditions, requires the developer to submit a waste management plan to the Environment Department. The plan must comply with the ‘Best Practice Guidelines on the Preparation of Waste Management Plans for C&D Projects’ issued by the DECLG and address the separation and management of wastes generated on site their recovery or disposal as well as addressing dust and noise issues. A planning condition requiring the developer to advise Limerick City Council of the WCP details of the hauling contractor(s) and the WFP details of any site(s) where material is proposed to be disposed of, is also included.
Reuse of C&D Waste & Recycling Facilities
Page 78 In relation to the re-use of C&D Waste the County Development Plans within the Region incorporated the target set out in this plan. These are outlined below:-
(a) The Clare County Council County Development Plan 2011 – 2017 CDP 9.7 states: It is an objective of Clare County Council: (b) To promote the production and reuse of aggregates from C&D waste and their use in construction projects in the Region;
(b) The Limerick City Council County Development Plan 2010 – 2016 Policy EM.9 states: It is the policy of Limerick City Council to reduce the generation of Construction & Demolition Waste and ensure that reuse and recycling of this waste is maximized in support of the implementation Plan for the Management of C&D in the Region.
In relation to encouraging the development of C&D recycling facilities at suitable sites, for example, quarries, the County Development Plans in the Region included the following:-
(a) The Clare County Council County Development Plan 2011 – 2017 CDP 9.7 states: It is an objective of Clare County Council: (c) To encourage the development of C&D waste recycling facilities at suitable sites, including quarries, subject to normal planning and environmental considerations.
(b) The Kerry County Council County Development Plan 2009 to 2015 Objective 13.19.7 states: Developers of quarries, both in functional sites and in the preparation of restoration plans should consider the provision of construction and demolition waste recycling facilities as well as accepting inert waste for use in the phased restoration of the site.
Targets to 2010:
The 2011 WCP annual returns show a 99% C&D recycling rate within the Region surpassing the EU target of 85% by 2013, therefore there are adequate C&D waste facilities in the Region.
During the construction boom years four of the main private waste collectors in the Region invested in infrastructure for the segregation and recycling of C&D waste which is an adequate number of facilities particularly as there has been a significant reduction in the quantity of C&D waste generated within the Region over the last number of years.
Recent Legislative Requirements:
In July 2006 the DECLG published ‘Best Practice Guidelines for the Preparation of Waste Management Plans for Construction & Demolition Projects’ which were
Page 79 subsequently given statutory footing in 2007 under Section 28 of the Planning & Development Act 2000.
The issue as to whether uncontaminated excavated soil should be considered a waste is dealt with under Article 11 of the Waste Directive (2008/98/EC) which states:
The waste status of uncontaminated excavated soils and other naturally occurring material which are used on sites other than the one from which they were excavated should be considered in accordance with the definition of waste and the provisions on by-products or on the end of waste status under this Directive.
The classification of uncontaminated excavated soil as a by-product or end of waste status in accordance with Regulation 27 or 28 of the EC (Waste Directive) Regulations, 2011 would significantly reduce the quantity of C&D waste generated within the Region, particularly as 64% of C&D Waste generated within the Region in 2011 was uncontaminated soil. The final outcome of the recent EPA consultation document will clarify this issue.
In relation to C&D re-use & recycling the EC (Waste Directive) Regulations 2011 defined objectives in Regulation 31 (2) which states:
(2) In order to comply with the objectives of the Waste Directive, and move towards a European recycling society with a high level of resource efficiency, and without prejudice to any other targets or obligations which may apply as a result of waste prevention and management legislation and policy, the Minister, the Agency and the Local Authorities shall, in carrying out their respective functions under the Act of 1996, take the necessary measures designed to achieve the following targets:
(b) by 2020, the preparing for re-use, recycling and other material recovery, including backfilling operations using waste to substitute other materials, of non-hazardous construction and demolition waste excluding naturally occurring material defined in category 17 05 04 in the list of waste shall be increased to a minimum of 70% by weight.
Environmental Considerations:
The proper and regulated classification of uncontaminated excavated soil as a by-product is essential in order to prevent the illegal dumping of contaminated excavated soil within the Region and subsequent negative environmental consequences i.e. biodiversity, water quality.
Recommendation:
Page 80 Growth may improve in this sector as the national economic growth increases therefore all future Regional waste management plans will need consider the EPA decision on by-products and a new policy on C&D waste needs to be developed to include prevention initiatives with clear objectives and targets on segregation at source of this waste stream. The EPA are also preparing guidelines regarding C& D statistics and the recommendations from these should be considered in any new C&D policy objectives and targets.
Page 81 9.0 OTHER PRIORITY WASTE STREAMS The European Union identified a number of priority streams including C& D waste already described. In this Region the other priority streams that have been monitored are
1. Hazardous Waste
2. Waste Electronic and Electrical Equipment (WEEE)
3. End of Life Vehicles(ELVs)
4. Tyres
There are separate policies relating to each stream included under Chapter 16 of the Plan. As mentioned in Chapter 6, the Region in an attempt to simplify waste matters for retailers published the booklet ‘Waste Legislation for Retailers’ to provide a concise source of the key points of different regulations, e.g. WEEE, Batteries, Hazardous Waste, ELVs, Tyres etc.. Central to these Regulations is the need for waste minimisation and waste prevention where possible and also segregation of wastes to aid recovery.
9.1 Hazardous Waste The policies, objectives and targets relating to Hazardous Waste are included in Chapter 16.2 of the plan
Policy:
To ensure that hazardous waste management is addressed through an integrated approach of prevention, recycling, treatment and disposal.
Objectives:
To improve awareness of the need to manage household and SME hazardous waste, through educational programmes on prevention, reduction, recycling and source separation
To provide adequate facilities for household hazardous waste at Recycling Centres
To improve the level of reporting and data collection on hazardous waste Targets to 2010:
Each Local Authority will run one public education campaign per year based around prevention, reduction, recycling and source separation of household and SME hazardous waste
Page 82 To develop storage facilities for household hazardous waste at all major Recycling Centres
Assessing Implementation
The EPA National Waste Report compiles data on the management of hazardous waste based on the location of treatment i.e. on-site at the industry where it was generated, off-site at facilities within Ireland and/or waste which is exported and imported for treatment (National Transfrontier Shipment Office - NTFSO). Total hazardous waste managed in Ireland in 2010 is 1% less than in 2009.
In relation to hazardous waste generated within this Region data is obtained from the WCP AER returns and the Table below shows the quantity of hazardous waste collected by permitted collectors within the Region for the period 2008 – 2010.
Note: the breakdown below only became available in 2008 with the introduction of the on-line AER return system.
Table 9.1 Breakdown of Quantity of Hazardous Waste Collected in Region 2008-2010 Waste Type 2008 2009 2010 (tonne (tonne (tonne s) s) s) Hazardous Commercial & 7,893 8,000 10,169 Industrial Hazardous Municipal 764 49 236
The quantity of hazardous commercial & industrial collected within the Region has increased year-on-year since 2008 while the hazardous municipal has seen a general decrease. These figures indicate activity within the commercial & industrial sector i.e. the manufacturing industry, the main contributor to this waste stream.
In relation to awareness of the need to manage household and Small and Medium Enterprises (SME) hazardous waste, the following measures have been taken:
In 2010 the RWMO, participants in the LAPN, working in partnership with the Region's Local Authorities developed the booklet ‘A Householders' Guide to Hazardous Waste Prevention’: This booklet contains tips and
Page 83 advice for householders on the correct use and disposal of everyday hazardous products.
There is also continued emphasis on recycling and hazardous waste awareness in the Region throughout the year, by the environmental awareness officers i.e. during European Week for Waste Reduction (EWWR).
In 2012 a new LAPN Project in Limerick City is focusing on municipal hazardous waste generation and is working with 25 households to assess the quantities of household hazardous waste in use and behavioural motivators for suitable alternatives.
At a business and industry level specific focus was also placed on hazardous waste described below:
Promotion through Case Studies Hazardous waste prevention among businesses was promoted through case studies in the Region’s publications, such as in the guide ‘Waste Prevention for Industry and Business’, which reached a wide business circulation through email contacts and distribution at events, as well as being accessible through the website www.managewaste.ie. Links to case studies on hazardous waste prevention are also being placed on the website.
Publications The leaflet ‘Minimising Hazardous Waste at Work’ was also widely distributed and an update of it was re-distributed recently incorporating changes in hazardous waste legislation.
The recent publication, ‘Waste Legislation for Retailers’ includes a specific Chapter on hazardous waste management.
Awareness Events
The RWMO sponsored an event run by the Institution for Occupational Safety and Health (IOSH), at which there was a speaker from Enva hazardous waste management site in Shannon
Hazardous waste prevention was also regularly covered in the annual waste forum run by the RWMO and Enterprise Ireland, which promoted the concept of waste prevention in all aspects, including hazardous waste.
Recent Legislative Requirements:
The EC (Waste Directive) Regulations, 2011 amended the definition for hazardous waste, given in the WMA 1996, to simply state:
Page 84 “hazardous waste” means waste which displays one or more of the hazardous properties listed in the Second Schedule’
The EPA, in accordance with Section 26 of the WMA 1996 is responsible for the preparation of the National Hazardous Waste Management Plan with the current plan covering the period 2008-2012. The Plan describes the national system for hazardous waste management and identifies gaps and recommends actions to ensure all hazardous waste is collected and managed appropriately and in a manner that does not cause environmental pollution. The current plan has a total of 29 recommendations.
The EC (Waste Directive) Regulations, 2011 requires that this plan is evaluated and revised if necessary at least once in a 6 year period (the WMA 1996 required that the plan be reviewed every 5 years)
There have been a number of legislative changes in relation to the control of the movement of hazardous waste in recent years and these have included the following:
Since 31st December 2011 the Waste Management (Movement of Hazardous Waste) Regulations 1998 (SI 147 of 2008) has been replaced by the European Communities (Shipments of Hazardous Waste exclusively within Ireland) Regulations 2011 resulting in the previously used C1 forms being replaced by the Waste Transfer Form (WTF) with Dublin City Council being the national authority for the administration of the WTFs
In July 2007 the Waste Management (Shipments of Waste) Regulations 2007 (SI 419 of 2007) came into effect. These Regulations gave effect to provisions contained in Commission Regulation (EC) No. 1013/2006 on transfrontier shipments of waste, which sets out new notification procedures, specifies revised waste listings and strengthens enforcement provisions in relation to waste movements within, into and out of the EU. Therefore since July 2007 all transfrontier shipments of waste originating in any Local Authority area in the State, that are subject to the prior written notification procedures, must be notified to and through Dublin City Council at the NTFSO established to implement and enforce the Regulations.
Environmental Considerations:
The mismanagement and/or illegal disposal of hazardous waste in the environment would have significant negative impacts on all medium i.e. water & air quality, climate, biodiversity and human health but this is inherently difficult to identify. Landfills are not designed to deal with hazardous wastes and therefore segregation of these wastes at source is paramount.
Page 85 Recommendation:
It is essential to continue to have a hazardous waste policy and the policy should consider the revised hazardous waste prevention plan in developing or amending the hazardous waste policy and objective and targets relating to business and household awareness need to be included. Data distribution from the NTFSO needs to be regularized in the future.
9.2 Waste Electronic and Electrical Equipment (WEEE) The policies, objectives and targets relating to WEEE are included in Chapter 16.3 of the plan
Policy:
The Local Authorities shall maximise the collection, reuse and recycling opportunities for all WEEE in the Region to meet the requirements of WEEE Regulations (S.I. 340 of 2005).
Objectives:
To raise awareness of WEEE amongst householders and the implications of the WEEE Regulations
To ensure major Recycling Centres accept WEEE from householders (and from retailers by prior arrangement)
To explore alternative WEEE collection methods with industry to ensure maximum coverage is provided for householders in the Region
To enforce regulation of waste collection activities, treatment and recycling facilities for WEEE by the private sector
Local Authorities will engage with the private sector in the development of WEEE recycling facilities.
Targets to 2010:
The Local Authorities shall regularly promote the options for reuse, repair and recycling of WEEE that are available in the Region
All major Recycling Centres in the Region shall accept all WEEE from 2006
Assessing Implementation
Page 86 WEEE waste generated within the Region is collected via the following routes:
At CAS sites/recycling centres. Note: All major CAS/recycling centres within this Region accept WEEE.
Retailer take-back scheme, operated at the point of sale.
European Recycling Platform (ERP) open days, which were introduced in this Region in 2008 with co-operation from the relevant Environmental Services Section i.e. 2008 - 33 open days, 2009 – 30 open days, 2010 – 30 open days
Authorised waste collectors
Since September 2008 batteries are collected at agreed collection points such as schools, public buildings and CAS.
In recent years the EAOs have worked closely with ERP to facilitate improved WEEE recycling at ‘Be Free Recycling’ events and run specific schools battery related projects eg Santa Grotto.
WEEE waste collected in this Region is sent to a dismantling site that then allows for the recovery of most of the components. There are a number of dismantling sites in Ireland but final recovery of the WEEE takes place mainly in the UK and the Netherlands.
In relation to WEEE generated within this Region the Table 9.2 gives the details of the quantities of WEEE collected in the Region from both recycling and take back schemes
Table 9.2 Quantity of WEEE Collected in Region 2008-2010 WEEE Source 2008 2009 2010 (tonn (tonne (tonne es) s) s) Recycling Centres (including take- 2,891 2,345 2,198 back scheme)
The national target for collection of WEEE was set at 4kgs/head but the national figure is now close to 10kgs/head and the figure for this Region has dropped from the high of 9.6kgs per head in 2008 to 8.2kgs/head in 2010 similar to the 2009 figure, due to lower consumption rates.
The enforcement of the WEEE Regulations is the responsibility of the relevant Local Authorities within the Region. As part of the inspections, premises are assessed to ensure that WEEE or batteries taken back by the premises are
Page 87 stored properly and consigned to appropriate authorised waste facilities. The Local Authorities liaises on an ongoing basis with the WEEE and batteries compliance scheme ERP Ireland on issues of common concern. Clare County Council has carried out awareness and enforcement activities to ensure that WEEE is not collected under so-called 'Scrap Saturday' collection events for waste metals. Limerick City Council typically carry out approximately ten inspections annually in accordance with their ‘Recommendation providing for Minimum Criteria for Environmental Inspections plan’ (RMCEI). Limerick County and Kerry County carry out inspections as part of joint inspection initiatives.
Table 9.3 below shows the number of inspections carried out within the Region for the period 2007 – 2010
Table 9.3: WEEE Inspections in the L/C/K Region in 2010 (Source RMCEI Review Data) TOTAL TOTAL TOTAL TOTAL 2007 2008 2009 2010 No. of WEEE 56 77 29 16 Inspections
The focus on enforcement activities within the Region reflects the priority areas and over the last number of years the number of WEEE Inspections has decreased as the retailers become more aware of their legal responsibilities in this area and the quantity of WEEE waste generated has decreased.
Recent Legislative Requirements:
The government introduced Regulations in August 2005 to ensure handling of WEEE waste in an environmentally sound manner. Waste Management (Waste Electronic and Electrical Equipment) Regulations, 2005 introduced a one-to-one take back system when purchasing electrical items. These Regulations including subsequent amendments in 2008 & 2010 have now been replaced by the European Communities Waste Electronic and Electrical Equipment) Regulations, 2011. The 2011 Regulations give further effect to the provisions of Council Directive 2002/96/EC as amended by Council Directive 2003/108/EC and Article 5 of Directive 2008/112/EC. They are designed to promote the recovery of WEEE in particular the achievement of the targets for the collection, treatment, recovery and disposal of WEEE in an environmentally sound manner.
In July 2012 the EU published the Waste Electrical and Electronic Equipment Directive 2012/19/EU and Member States will have to amend their existing legislation on WEEE and align it with the new Directive and the new targets by February 2014. From 2016 onwards, Member States will be required to ensure
Page 88 that 45% of electrical and electronic equipment sold in each country is collected and from 2018 the scope of the Directive is widened from today's categories to all electrical and electronic equipment. From 2019 onwards, the collection target is raised to 65% of electrical and electronic equipment sold, or the alternative measure of 85% of WEEE generated or roughly 20kg per capita.
In September 2008 the Waste Management (Batteries & Accumulators) Regulations 2008 as amended (i.e. SI 268 of 2008 & SI 556 of 2008) came into force to ensure the environmentally sound disposal of batteries financed by the producers. Take back is on a one for zero basis that means members of the public are not obliged to make a purchase when depositing waste batteries at retail outlets. Batteries can also be deposited at agreed collection points such as schools, public buildings and CAS.
Assessment of Legislative Requirements:
There are now a number of legislative requirements in place specifying specific producer/holder responsibilities in relation to WEEE, thus providing a framework for maximising WEEE collection. The recent Waste Management Policy (July 2012) has stated that the producer responsibility initiative review will examine the issue of a reuse policy for WEEE However, the continuing enforcement of the legislation is essential to ensure the proper management of this waste stream.
Environmental Considerations:
As a number of WEEE items are hazardous in nature their secure collection & storage prior to dismantling is crucial in order to avoid negative impacts on the environment.
Recommendation:
The current policy was based on the previous legislation so therefore needs be amended to consider the new targets as set out in the revised directive. Therefore continuing effort needs to be made to ensure WEEE collection is maximised and that there is maximum coverage for households within the Region. Continuing enforcement of the legislation will also be paramount.
9.3 End of Life Vehicles(ELVs) The policies, objectives and targets relating to ELVS are included in Chapter 16.4 of the plan
Policy:
To ensure that ELVs are dismantled and recovered in a manner which does not cause environmental pollution and ensure that the recycling and recovery rates of ELVs and their components are met.
Page 89 Objectives:
Producer Responsibility
To increase the recovery and recycling rates of ELVs and their components and meet the targets specified by the Directive
To minimise the use of hazardous materials/substances in vehicles and components
To increase the use of recycled materials in the manufacture of vehicles
Objectives:
Local Authority
To ensure that abandoned and burnt-out cars collected by or on behalf of the Local Authorities are brought to waste permitted facilities for recovery and disposal
To enforce and regulate waste collection permit and waste permit holders in the Region and ensure that accurate records and reporting are maintained
To ensure the public are aware that all ELVs should be disposed of in an environmentally sound manner at fully permitted facilities or suitably approved collection points
Targets to 2010:
The Local Authorities shall run regular public education campaigns focusing on the public’s obligation, to coincide with implementation of the Directive, to dispose of their vehicles appropriately
The enforcement team in each Local Authority shall perform audits, every second year, of the waste collection permits and waste permit holders to ensure accurate records are kept.
Assessing Implementation
The quantity of ELVs collected within the Region during the period 2008 – 2011 is detailed in Table 9.6 below. Despite the economic downturn there has been a steady increase in the quantity of ELVs collected within the Region. It should be noted, however that the increase maybe in part attributed to improved recording keeping by significant collectors within the Region, following audits of the collectors annual returns.
Page 90 Table 9.4: Quantity of ELVs collected within the Region for the period 2008 – 2011 Waste 2008 2009 2010 2011 Type (tonnes) (tonnes) (tonnes) (tonnes) ELV's 13,120 15,646 21,267 24,879 Note: the breakdown below only became available in 2008 with the introduction of the on-line AER return system.
The 24,879 tonnes of ELVs collected in the Region for 2011 is the equivalent of 1 in every 7 households disposing of a car in 2011.
The ELV Regulations introduced new environmental standards so that when a car is scrapped, as much material as possible is recovered and recycled and it takes place in a way that does not harm the environment. 99% of ELVs collected in the Region in 2011 were sent for recovery however it is difficult to ascertain the reuse/recovery targets in the regulations.
Enforcement:
The enforcement of the ELV Regulations is the responsibility of the relevant Local Authorities within the Region. The relevant Local Authorities within the Region enforce the WFPs & WCPs and have been actively enforcing those with respect to ELVs over the lifetime of the plan particularly during the earlier years of the implementation of the Regulations.
For example in Clare County Council a risk-based or themed approach to waste collection auditing, reflecting waste enforcement priorities and issues that may arise is generally employed. For example, the council focused on ELVs and waste tyres collectors in 2011, reflecting national and local waste enforcement priorities in that year.
Limerick County Council actively enforce the WFP’s and WCP’s by dealing with complaints, carrying out scheduled inspections and audits in accordance with the RMCEI plan, with subsequent issuing of warning letters, notices and taking prosecutions where applicable and providing ‘Certificate of Destruction Books’ to permitted facilities.
Limerick City Council audits ATF’s annually and relevant WCPs at least every 2 years. In 2012 Limerick City Council commenced weekly checks on incoming waste records at two metal recycling facilities in the city.
Kerry County Council are continuing enforcement on illegal ELV sites as well as auditing authorised sites.
Table 9.5 below shows the number of ELV inspections carried out within the Region for the period 2007 – 2010
Page 91 Table 9.5: ELV Inspections in the L/C/K Region 2007- 2010 (Source RMCEI Review Data) TOTAL TOTAL TOTAL TOTAL 2007 2008 2009 2010 No. of ELV Inspections 132 135 63 28
As unauthorised ELV sites, within the Region, became authorised or closed down over the last number of years the number of ELV inspections carried out have shown a subsequent decrease. However it should be noted that the Local Authorities within this Region have allocated a significant amount of resources, over the last number of years in authorising ELV sites to ensure compliance with the ELV Regulations and the European Court of Justice case ruling (ECJ C494/01). Almost all identified unauthorised ELV sites within the Region, from November 2010, have now either been closed or regularised.
Recent Legislative Requirements:
The Waste Management (End of Life Vehicle) Regulations 2006 were introduced in June 2006 and these imposed substantial obligations on producers, Local Authorities, Authorized Treatment Facilities (ATF) and on vehicle owners. The Regulations also introduced environmental standards in relation to the reuse/recovery rates for ELV’s i.e. each producer has to have 95% reuse/recovery with 85% reuse/recycling by average weight per vehicle and year by 1st January 2015.
The 2006 Regulations were amended by the European Communities (End-of-Life Vehicles) (Amendment) Regulations 2011, which came into effect on 31st December 2011 to give effect to Commission Directive 2011/37/EU amending Annex II to Directive 2000/53/EC, which lists the materials and components of vehicles which can use lead, mercury, cadmium or hexavalent chromium.
The recent Waste Management Policy (July 2012) stated that the exemption from the landfill levy for shredder residue is being removed to support the achievement of ELV recycling and recovery targets.
The European Court of Justice case ruling (ECJ C494/01) in relation to unauthorised ELV sites required all ELV sites to be appropriately permitted and appropriate action taken against unauthorised ELV sites. Almost all identified unauthorised ELV sites within the Region, from November 2010, have now either been closed or regularised.
Assessment of Legislative Requirements:
Page 92 The ELV Regulations impose substantial obligations on all relevant sectors and the active enforcment by Local Authorities is essential to ensure compliance and prevent unauthorized activity.
Environmental Considerations:
Unauthorised ELV sites have the potential to have a significant impact on all aspects of the environment, particularly due to the hazardous nature of the ELV components. Oil leakage to groundwater was a feature of these facilities prior to the installation of the infrastructural requirements of the ATF permits.
Recommendation:
Although almost all identified unauthorised ELV sites within the Region, from November 2010, have now either been closed or regularised however there is an on-going issue of new unauthorised ELV sites coming to the attention of Local Authorities due to the potentially lucrative spin-offs from this industry. Therefore extensive resources shall continue to be required in order to properly regulate this area.
Ireland’s failure to meet the EU re-use and recovery targets for ELVs shall have to be addressed and indicates that the producer responsibility initiative developed in relation to ELVs has not contributed effectively to it’s intend purpose, therefore the legislative arrangements would benefit from re-design.
The plan policy needs to be amended to take account of new legislation and the continuing issues related to unauthorized sites.
9.4 Tyres The policies, objectives and targets relating to tyres are included in Chapter 16.5 of the plan
Policy:
To minimise the illegal disposal of waste tyres and increase the quantity of tyre recycling.
Objectives:
To ensure that waste tyres are collected and recycled through the recognized channels
Page 93 Assessing Implementation
While waste tyres are not classified as hazardous waste, they can cause environmental pollution if disposed of incorrectly or irresponsibly. An estimated 35,000 tonnes of waste tyres are generated in Ireland each year. Waste tyres can be put to many beneficial uses when they reach their end of life. The rubber from shredded tyres has many uses, such as in playgrounds, as equine bedding or on football pitches. Furthermore the steel recovered from recycled tyres is a valuable resource.
On 1st January 2008 the Waste Management (Tyres and Waste Tyres) Regulations 2007 came into force. These Regulations are designed to promote the environmentally sound management of waste tyres. Table 9.6 below shows the quantity of tyres collected, by permitted collectors, within the Region for the period 2008 – 2011. (Note: the breakdown below only became available in 2008 with the introduction of the on-line AER return system.)
Table 9.6: Quantity of Tyres collected within the Region for the period 2008 – 2011 Waste 2008 2009 2010 2011 Type (tonnes) (tonnes) (tonnes) (tonnes)
Tyres 1,751 1,747 1,320 2,221
The 2011 figure shows a significant increase in the quantity of waste tyres collected within the Region compared to 2010 i.e. 40% increase. This increase appears to be linked to an increase in the number of active permitted collectors within the Region in 2011.
The enforcement of the Tyre Regulations is the responsibility of the relevant Local Authorities within the Region. Table 9.7 below shows the number of inspections carried out within the Region for the period 2009 - 2010
Table 9.7: Tyre Inspections in the L/C/K Region in 2009-2010 (Source RMCEI Review Data) TOTAL TOTAL 2009 2010 No. of Tyre 39 80 Inspections
The number of tyre inspections increased by over 50% in 2010 due to a focus on waste tyre collectors within the Region as the issue was highlighted as being a
Page 94 waste management concern in terms of storage and use in the rural environment. It was also identified that there were not many disposal options available for the quantity of waste tyres produced in Ireland.
During 2011 the Region put together an information leaflet focusing on waste tyre collector’s responsibilities under the 2007 Regulations. A copy of the leaflet was forwarded to all permitted waste tyre collectors in the Region which raised awareness of their responsibilities.
Recent Legislative Requirements:
The Waste Management (Tyres and Waste Tyres) Regulations 2007, which came into force on 1st January 2008, are designed to promote the environmentally sound management of waste tyres. The Regulations impose obligations on persons who supply tyres to the Irish market, whether as manufacturers, wholesalers, suppliers, traders, or retailers and on the collectors of waste tyres. These obligations include the submission of information as prescribed in the Regulations and in the format provided for in the Guidance by the 10th day of each quarterly period. They are also required to prepare and present waste management plans and reports when submitting applications for registration and submit a report to the EPA by the 28th February of each year.
The aim of the Regulations was to support the environmentally sound management of waste tyres by providing a regulatory framework for comparing quantities of waste tyres arising with the quantities placed on the market and in tracking the movement of waste tyres from the time they are discarded until they are either reused or processed for recycling and /or recovery. TWA (Tyre Waste Management Ltd) and TRACS (Tyre Recovery Activity Compliance Scheme) are tracking compliance schemes set up to meet the requirements of the Regulations.
Assessment of Legislative Requirements:
Page 95 The producer responsibility initiative developed in relation to tyres has not contributed effectively to its’ intended purpose therefore the legislative arrangements would benefit from re-design. The established compliance schemes have been ineffective in providing up to date information on tyre movements
Environmental Considerations:
While waste tyres are not classified as hazardous waste, they can cause environmental pollution if disposed of incorrectly or irresponsibly and aesthetically are unappealing.
Recommendation:
The producer responsibility initiative developed in relation to tyres has not contributed effectively to it’s intend purpose therefore the legislative arrangements would benefit from re-design. The plan policy will need to be amended accordingly.
9.5 Sludges The policies, objectives and targets relating to sludges are included in Chapter 16.6 of the plan
Policy:
To implement the policies as stated in each Sludge Management Plan.
Objectives:
To develop hub centres for the treatment of municipal wastewater sludge
To designate satellite centres which would export sludge to the hub centre
To promote the use of biosolids arising from municipal wastewater treatment plants as fertiliser and other beneficial uses Targets to 2010:
Targets are set out in the Sludge Management Plans
Assessing Implementation
All Local Authorities now have individual sludge management plans in place. The sludge management plans address the management and control of waste water
Page 96 sludge in a progressive and environmentally sustainable way and advise on the most appropriate means of managing sewage sludge arising within each county or city. The plans consider sludge quality and quantities, availability of suitable land for re-use, all re-use options, storage and transportation. ( Note :Sludge Management Plans do not require public consultation unlike waste management plans)
Local authorities maintain a register of all sludge/biosolids movement and use and require advance notification of proposed land banks to be used for biosolids spreading. Any person using biosolids in agriculture is required to do so only in accordance with an approved nutrient management plan and the DECLG’s Code of Good Practice.
Table 9.8 below shows the quantity of sludges collected, by permitted collectors, within the Region for the period 2008 – 2011. (Note: the breakdown below only became available in 2008 with the introduction of the on-line AER return system.)
Table 9.8: Quantity of Sludge collected within the Region for the period 2008 – 2011 Waste Type 2008 2009 2010 2011 (tonnes) (tonnes) (tonnes) (tonnes) Sludges from treatment of 32,333 19,550 28,191 29,638 urban waste water Sludges from water 5,798 6,171 24,741 3,682 clarification Septic tank sludges 1,202 3,532 3,948 4,234
Despite a drop in the quantity of sludge collected from urban wastewater plants in 2009 the quantity collected in 2011 is similar to 2008 and 2010.
The quantity of sludge collected from water treatment plants increased significantly in 2010 due to specific maintenance works at a water treatment plant in Co. Limerick which accounted for over 80% of the sludges from water clarification generated in 2010.
The quantity of septic tank sludges collected has increased year-on-year since 2008 and this is likely to continue to increase as a result of increased public awareness of the need to empty septic tanks on a regular basis following the publication of the Water Services (Amendment) Act 2012.
Recent Legislative Requirements:
Page 97 The Waste Management (Registration of Sewage Sludge Facility) Regulations 2010 provide for the registration and regulation of sewage sludge facilities in order to meet the requirements of the Waste Management (Use of Sewage Sludge in Agriculture) Regulations,1998 as amended. Facilities already regulated under other environmental legislation such as licensed facilities under the WMA 1996 are excluded.
Under these Regulations the Local Authorities are required to maintain a register of sludge storage facilities and can attach conditions of operation to any facility it registers.
Waste Management (Use of Sewage sludge in Agriculture) Regulations, 1998 to 2001 specify limits on the amount of dry matter to be added to soil, based on absolute quantities of specified heavy metals. The Regulations also require that sludge is used in accordance with a nutrient management plan and provide for the inclusion of additional technical parameters to be entered in the sludge register provided for in the 1998 Regulations.
The Water Services (Amendment) Act 2012 requires water services authorities to maintain a register of domestic waste water treatment systems in their functional areas. The Local Government Management Agency (LGMA) has developed a central on-line registration system and will manage the system on a shared-service basis for the water services authorities. Under the Act, owners of domestic waste water treatment systems are required to ensure that their systems are on the register, before 1st February 2013. The EPA will then develop an inspection system for domestic wastewater treatment systems, which is due to commence in 2013.
Environmental Considerations:
Sludge originates from the process of treatment of waste water. Due to the physical-chemical processes involved in the treatment, the sludge tends to concentrate heavy metals and poorly biodegradable trace organic compounds as well as potentially pathogenic organisms (viruses, bacteria etc) present in waste waters. Sludge is, however, rich in nutrients such as nitrogen and phosphorous and contains valuable organic matter that is useful when soils are depleted or subject to erosion. The organic matter and nutrients are the two main elements that make the spreading of this kind of waste on land as a fertiliser or an organic soil improver suitable. The treated sludges must be disposed of in accordance with regulations to avoid an excess of nutrients such as N and P which can contribute to eutrophication of water bodies.
Page 98 Recommendation:
The policy in the plan needs to reflect the sludge waste management plans which require updating to take into account new legislations and technologies. Kerry County Council has included this update in their County Development Plan. As these sludge plans do not require a public consultation phase their inclusion in future waste plans may be inappropriate.
Page 99 10.0 INFRASTRUCTURE The EC (Waste Directive) Regulations, 2011amended Section 37 of the WMA 1996 by including the following in relation to self-sufficiency and proximity:- In carrying out their respective functions under this Act and related waste prevention and management legislation and policy, the Minister (in cooperation with other Member States where this is necessary or advisable), the Agency, An Bord Pleanála and the local authorities shall take appropriate measures to establish an integrated and adequate network of waste disposal installations and of installations for the recovery of mixed municipal waste collected from private households, including where such collection also covers such waste from other producers, taking into account best available techniques.
The L/C/K Region has a number of public and privately operated recovery and disposal waste infrastructural developments which accept and process household waste, commercial waste, C&D wastes, ELVs and compostable waste. These developments include:
Bring Banks
Recycling Centres/Civic Amenity Sites/Transfer Stations
Material Recovery Facilities (MRFs) and Transfer Stations:
Authorised Treatment Facilities (ATFs)
Composting facilities
Landfills
The above facilities operate either under either a waste license or CoR from the EPA or WFP from the relevant Local Authority. The authorisation specifies the waste types and quantities acceptable at the site.
In addition to the above developed infrastructure, the private sector has shown interest in developing thermal treatment infrastructure in this Region over the past number of years.
Page 100 10.1 Bring Banks
Bring banks are located in numerous locations throughout the Region and accept non-hazardous source segregated recyclable waste, primarily glass, aluminum & steel cans.
The plan policy related to bring banks is included under Chapter 15.3 (Reuse and Recycling Policy) and specific objectives and targets relating to bring banks were set as follows:
Objectives:
Bring Banks will continue to be distributed throughout the Region
Local Authorities will continue to improve management and maintenance at bring bank facilities
Additional bring banks will be provided with a range of facilities to meet demand where it is practical and subject to availability of resources
Targets
32 additional bring banks, of which 10 will be in Clare, mainly to fill gaps in the east and south east of the county, 9 in Kerry, 8 in Limerick County and 5 in Limerick City, shall be provided in optimal locations throughout the Region by 2010 subject to funding.
Assessing Implementation
In June 2006 there were 215 bring banks within the Region and by December 2011 there were 231 bring banks in the Region (2011 NWR) which is the highest number of bring banks in the Region since the start of this plan.
Details on progress, in relation to the roll-out of bring banks, since 2006, are shown below
Table 10.1 Bring Bank (BB) Numbers
Page 101 Local Authority No. No of No. No. No. No. No. of of BB of of of of BB BB June BB BB BB BB require June 2007 June June June Dec d to 2006 2008 2009 2010 2011 meet (201 plan 1 target NWR )
Limerick City Council 19 18 19 20 21 22 2
Limerick County 50 51 49 48 51 50 8 Council
Kerry County Council 93 103 103 103 103 105 0
Clare County Council 53 54 55 53 53 54 9
Total Region 215 226 226 224 228 231 16
Although Kerry County Council exceeded the additional bring bank target specified in the plan, the Region as a whole reached 50% of the target that was set for the Region in 2006. This progress is significant and indicates that the original target may have been overly ambitious particularly as there has been a significant roll out of the kerbside mixed dry recyclable collections.
There are a number of Local Government Service Indicators relating to bring banks (Tables 13-18 of the ‘Services Indicators in Local Authorities Annual Report’ are applicable). The median average for the country in 2011, according to the Services Indicators in Local Authorities Report 2011, is 42 bring banks per Local Authority. The average number of bring banks per Local Authority for this Region, from Table 5.6, is 57, well above the average rate for the country. Table 13 of the ‘Services Indicators in Local Authorities Annual Report’ details the number of glass recycling locations (per 5,000 of population with the median for the country in 2011 of 2.5 facilities per 5,000 of population. The current average rate of facilities in this Region is 2.7 units per 5,000 of population again this is slightly above the national average.
Local Authorities improved the management of bring bank facilities over this plan period and many introduced CCTV to assist in monitoring use of the facilities. Signage was also improved at bring banks
10.2 Recycling Centres/Civic Amenity Sites/Transfer Stations:
Page 102 For the purposes of this review Recycling Centres and Civic Amenity Sites (CAS) are taken to mean facilities where a wide range of waste materials may be presented for recycling/reuse/recovery, with emphasis on bulkier items and items that are not catered for by segregated kerbside collection services. These may be dedicated stand alone facilities or may be co-located with disposal facilities such as waste transfer stations or landfills. Note: in the case of Kerry County Council the CAS are known as transfer stations.
These sites have assisted the Local Authorities in reaching the recycling targets for the Region. The types of wastes accepted at these sites has expanded over the period of this plan and some of these sites now have charges and other sites only charge where residual waste is being dropped off. The plan policy relating to recycling centres is included under Chapter 15.3 (Reuse and Recycling Policy) and specific objectives and targets relating to recycling centres were set as follows
Objectives
Opening hours at recycling centres will be reviewed to reflect usage and demand where local conditions allow.
Local Authorities will engage with the private sector regarding the provision of public waste recycling amenities where appropriate. Targets
Provision of small scale Recycling Centres in rural areas will be based on the results of the survey
Additional Recycling Centres will be located in Mungret and Shannon by the end of 2006
1 Additional Recycling Centre will be located in Limerick City by the end of 2007
5 Additional Recycling Centres will be located in Dingle, Listowel, Killarney, Tralee and South East Clare by 2010
There has been no increase in the number of recycling centres in the Region since 2008. Table 10.2 shows the number of recycling centres at the commencement of the plan and at the end of 2011
Table 10.2 Recycling Centre Targets Local Authority No of Recycling Recycling No required Centres at the Centres in to meet
Page 103 commencement place end plan target of the plan 2011 Limerick City Council 1 Mini-Recycling 1 Mini-Recycling 1 (currently centre Centre no recycling centre in Limerick City) Limerick County 3 Recycling 5 Recycling 0 Council Centres Centres (includes 1 privately operated site)
Kerry County Council 5 Recycling 8 Recycling 2 (currently Centres Centres – no recycling (includes 2 centres in privately Killarney or operated sites) Listowel)
Clare County Council 4 Recycling 5 Recycling 1 (currently centres centres no recycling centre in South East Clare)
There is unlikely to be any immediate further investment in recycling centres due to budget constraints on Local Authorities.
In relation to the specific Recycling Centre targets specified in the plan the following have been met:
- Recycling centres have been opened in Mungret, Shannon & Dingle.
- All major recycling centres in the Region now accept WEEE, household hazardous waste and green waste
- Opening hours at recycling centres reflect usage and demand, for example all recycling centres in Co. Clare, Co. Kerry & Co. Limerick open on Saturday & during lunch hours.
However the additional recycling centres targeted for Limerick City, South East Clare, Killarney, Listowel and Tralee have not been met and as stated above there is unlikely to be any further investment in recycling centres due the closure of the government grant assistance scheme (EU, DEHLG & Environment Fund) and budget constraints on Local Authorities. However it should be noted that there are currently two privately operated civic amenity sites in Tralee and one within the environs of Limerick City therefore Local Authority recycling centres within these areas may no longer be required. Furthermore it is apparent
Page 104 that the Limerick County Council facility at Mungret is capable of meeting the needs of Limerick City as well as much of South East Clare regarding CAS provision.
10.3 Material Recovery Facilities (MRFs) and transfer stations:
The plan policy relating to MRFs is included under Chapter 15.7 and specific objectives and targets relating to MRFs were set as follows
Policy
The Local Authorities will support the development of additional MRF and Waste Transfer facilities where these can be shown to be consistent with the overall objectives of the Plan.
Objectives
If demand requires, additional MRF and/or Waste Transfer Stations will be provided in the Region. Targets
To ensure the provision of adequate MRF/Waste Transfer Station capacity to meet the Plan targets.
There are a number of privately operated Material Recovery Facilities (MRFs) and transfer stations within the Region and these include:
Clare Waste and Recycling Co. Ltd., Raheen, Tuamgraney, Co. Clare. (WFP- CE-08-0002-01),
Clean (Irl) Refuse and Recycling Co. Ltd., Cree, Kilrush, Co. Clare (002/07/WPT/CL),
Clean (Irl) Refuse and Recycling Co. Ltd., Shannon, Co. Clare (WFP-CE-08- 0003-01),
Dillon Waste, The Kerries, Tralee, Co. Kerry (WFP KY 10-001).
Higgins Waste & Recycling Services Ltd. , The Kerries, Tralee, Co. Kerry (WFP KY 50-04-2009),
Page 105 Greenstar Environmental Services Ltd., Dock Road, Limerick (W0082-02),
Killarney Waste Disposal, Aughnacureen, Killarney, Co. Kerry (W0217-01),
South West Bins on Wheels Ltd., Galvone Industrial Estate, Limerick (WFP- LKC-12-001-01)
Valcroft Ltd. - formerly Mr. Binman Ltd., Luddenmore, Co. Limerick (W0061-02),
William Fitzgerald, Rathbane North, Limerick (WFP-LKC-11-002-01)
Table 10.3 details the annual tonnage of waste which can be accepted at each of the sites according to the facility’s authorization limit.
Table 10.3 Waste Facility & Licence/Permit Processing Limit
Facility Name Licence/Permit Processing Limit (t) Clare Waste 13,000 Clean Irl (Cree) 21,000 Clean Irl (Shannon) 10,200 Dillon Waste 32,500 KWD 40,000 Mr. Binman 105,000* Greenstar 90,000 Higgins 4,425 William Fitzgerald 7,500 South West Bins 24,500 (Galvone) TOTAL 348,125
*The Mr Binman facility has a licensed capacity of 105,000 tonnes p.a. however its output is currently limited to 5,000 tonnes p.a. approx. by planning permission. A retention planning notification to operate at a through put of 24,999 tonnes p.a. has been issued with Limerick County Council
Page 106 The facilities listed above are currently licenced/permitted to process 348,125 tonnes of non-hazardous waste per year, with the exact waste types permitted specified in the relevant waste licence/waste facility permit. Copies ofthe relevant authorizations are available via the following links http://www.epa.ie/wastepermit/search/ and http://www.epa.ie/terminalfour/waste/index.jsp
Authorised processes at the above facilities include the following:
Sorting, separation and processing of mixed dry recyclables collected from municipal waste streams through use of magnets, vibrating screens, ballistatic separators and picking lines
The sorting and separation of waste to recover organic substances such as paper and cardboard, plastics, wood, and biodegradable waste (kitchen and canteen waste).
Processing of residual waste to produce refuse derived fuel (RDF) i.e. shredding & trammelling to remove organic fines, suitable for recovery, followed by a series of magnets and eddy current separators to remove ferrous and non-ferrous metals for recycling.
Sorting of metals from other wastes.
Sorting of C&D waste through use of trammels, magnets & picking lines to recover organic substances, inorganic materials and metals.
Timber shredding for use either as a compost bulking/aeration agent, or as raw material for chipboard/MDF manufacturers.
Glass processing through use of magnets, vibrating screens and crushers, to produce a high quality cullet
Bulking up of municipal solid waste
Baling, wrapping and transferring of recovered and residual materials to appropriately licensed recycling, recovery and disposal outlets
It should also be noted that a number of the authorized facilities also accept waste, at their site, from members of the public.
In 2011 approximately 322,800 tonnes of non-hazardous waste was processed at the above facilities. It should be noted that some of this waste may have originated from other Waste Regions.
Hazardous waste is not accepted at any of the above facilities.
Page 107 As the current licensed/permitted processing MRF capacity within the Region exceeds the quantity of non-hazardous waste processed in 2011 the target specified in the plan has been met.
10.4 Authorised Treatment Facilities (ATFs) The policies, objectives and targets relating to ELVS are included in Chapter 16.4 of the plan
Policy:
To ensure that ELVs are dismantled and recovered in a manner which does not cause environmental pollution and ensure that the recycling and recovery rates of ELVs and their components are met.
Objectives:
Producer Responsibility
To ensure that by 2007 the relevant motor industry operators establish treatment/recovery systems for all ELVs at no cost to the final holder
To ensure that all ELVs are dismantled and recovered in a manner which prevents waste generation and does not cause environmental pollution Objectives:
Local Authority
Local Authorities will encourage the development of ELV recycling facilities
The infrastructure for the processing of ELVs primarily resulted following the Waste Management (End of Life Vehicle) Regulations 2006 which imposed substantial obligations on ELV facilities and Local Authorities.
The number of ATFs in the Region has grown since 2006 and the car manufacturers have now recognized that there is need to contract with a permitted ATF to complete the registration process. Table 10.4 indicates the increased level of activity within this sector, over the last number of years:
Table 10.4: ATFs in the L/C/K Region Local Authority No. No. No. No. No. Area of of of of of
Page 108 ATF ATFS ATFS ATF ATF S (June (June S S (Jun 2009) 2010) (Jun (July e e 201 200 201 2) 8) 1) Limerick City Council 2 2 2 3 2 Limerick County 2 6 8 10 9 Council Kerry County Council 9 12 13 9 12 Clare County Council 0 1 2 4 4 TOTAL FOR REGION 13 21 25 26 27 The ATF’s are permitted to operate by the relevant Local Authority and Table 10.5 details the current permitted processing capacity within the L/C/K Region:
Table 10.5 Current permitted processing capacity within the L/C/K Region Local Authority Area Permitted processing capacity Clare 810 No. ELV/year Kerry 5,800 t/year Limerick City 7,605 t/year Limerick County 184 - ELV Storage Limit at any one time Despite the above development the requirement of ATF’s to issue certificates of destruction (CoD) for each deposited ELV has been problematic primarily due to illegal activity in the area and subsequent lack of log-books/vehicle licensing certificate for ELVs to allow for the issuing of CoDs.
10.5 Composting facilities:
There are currently only four permitted facilities within the L/C/K Region authorized to process compostable waste and these are:
Cremins Farm Compost Ltd., Broadford, Co. Limerick (WFP/LK/2009/23A/R2), which is an aerobic composting facility and is limited to storing a maximum of 6,000m3 of waste and compost at the site at any one time.
David McDonnell, Shanagolden, Co. Limerick (WFP/LK/2009/50/R1), which is an anaerobic digestion facility and is limited to accepting 10,000 tonnes of bio-waste per year.
Page 109 Limerick County Council Green Waste Facility, Mungret, Co. Limerick (EPA R02188-02), which is an aerobic composting facility with a max storage on site capacity of 2,000m3.
Clare County Council Green Waste Facility, Central Waste Management Facility, Ballyduff Beg, Inagh, Co. Clare (EPA W109-02), which is an aerobic composting facility and is limited to accepting 2,000 tonnes of source segregated green and organic waste per year.
A number of the larger waste operators within the Region are currently in the process of investigating the feasibility of developing composting facilities with some at an advanced stage. In the interim a large quantity of the segregated organic waste generated and collected within the Region is transported outside of the Region for composting.
10.6 Landfi lls:
The first L/C/K Waste Management Plan (2001) aimed to reduce the Region’s over dependence on landfill through waste prevention, re-use and recycling. The current Plan set a target to reduce landfilling of the total household, commercial and industrial waste arisings to 14%.
In relation to landfill disposal the Chapter 15.8 of the plan states the following:
Policy:
Landfills will be developed and operated to the highest international standards in accordance with Waste Licences issued by the EPA.
• To ensure that there is adequate landfill capacity in the Region.
The waste hierarchy is now established in European and Irish Law and therefore landfill disposal is bottom of the hierarchy and hence the least favoured option. It is hoped that prevention programmes will reduce the amount of waste available for landfill and that alternative options are developed without delay.
There are currently two Local Authority operated landfills within the Region which are licensed by the EPA. The Ballyduff-Beg Landfill, operated by Clare County Council, ceased accepting waste in November 2011 however the recycling facility at the landfill remains open. Table 10.6 below shows the remaining landfill capacity in the Region at October 2012.
Table 10.6Remaining Landfill capacity Limerick/Clare/Kerry Region (October 2012) Landfill Capacity Limerick County Kerry County Region
Page 110 Council- Council-North Total Gortadroma- Kerry Landfill Tonnes Landfill Tonnes Tonnes Capacity in cells 145,000 114,970 259,970 developed
It is now envisaged that both remaining landfills will cease accepting waste by mid to end of 2013. The developed cells in both landfills are expected to be full at that stage. The average amount of waste landfilled in the Region over the last three years is 167,781 tonnes per annum and the actual 2011 figure was 178,686 tonnes
A comparison of waste landfilled in each of landfills in the Region is shown below:- Table 10.7 L/C/K Region Tonnage of Waste Accepted at Landfill (2006- 2011)
Gortadroma- Ballyduff-Beg North Kerry Totals for Landfill (Co. Landfill (Co. Landfill (Co. the Year Limerick) Clare) Kerry) Region
Licenc e Limit (t) 130,000 56,500 77,000 263,500
2006 (t) 82,119 33,712 60,025 175,856
2007 (t) 39,577 46,289 56,794 142,660
2008 (t) 56,070 33,324 62,402 151,796
2009 (t) 103,834 25,695 39,755 169,284
2010 (t) 112,700 21,700 20,987 155,387
2011 (t) 129,995 30,692 18,000 178,686
Gortadroma remains the busiest landfill in the Region due to a gate fee advantage arising from the economies of scale going with the larger licensed tonnage limit. The financial viability of the North Kerry Landfill has been challenged by the reducing volumes of waste in the Region.
Page 111 Landfills are still the main disposal route for residual waste generated within the Region. Recently routes to Europe have opened up for residual waste to be exported to incineration plants with energy recovery.
Developing further landfill void space in the Region does not appear to be viable currently due to the following:-
1. Low landfill gate fees
2. Increases in the landfill levy
3. Further restrictions on BMW to landfill
4. Funding and repayment restrictions.
The target in the plan of ensuring adequate landfill capacity was available during 2006-2011 was met, this target is not realistic going forward.
10.7 Historic Closed Landfills:
The Waste Management (Certification of Historic Unlicensed Waste Disposal and Recovery Activity) Regulations 2008, published in December 2008 required Local Authorities to prepare an inventory of closed landfills and as a minimum carry out a tier one risk assessments of the sites. The register of closed landfills, within this Region, has been in place since 2004 and has been updated annually.
The Local Authorities in this Region have now identified 42 closed landfill sites, all of which have now completed Tier 1 risk assessments in accordance with the EPA code of practice classifying the sites as either High Risk (HR), Medium Risk (MR) or Low Risk (LR). More detailed on site investigations have commenced at a number of sites and these Tier 2/3 assessments are on-going.
Table C1 (Appendix C) indicates the current position regarding closed landfills. The RWMO applied, to the DECLG, for funding in 2009, 2010 and 2011 and over €150,000 of grant aid has been awarded.
The Minister in April 2012 agreed with the European Commission to provide funding for investigation and remediation of landfills in operation between 1977-1997, from voted expenditure as necessary to support works required to bring the European Court Judgement case (ECJ 494/01) to a close, however to- date no new grant aid has been awarded in 2012.
It is proposed that the application process be subject to a phased approach where incremental targets are achieved over a 6 year time frame. In order to achieve certification for all sites concerned submissions to the EPA are now requested from all Local Authorities so as to satisfy the timelines specified in the DECLG Circular WP 15.12 issued in August 2012 which places an equal emphasis on all three risk categories.
Page 112 . End of 2012 10 HR 10 MR 10 LR = 30
. End of 2013 20 HR.20 MR. 20 LR = 60
. End of 2014 20 HR. 20 MR. 20 LR = 60
. End of 2015 20 HR. 20 MR. 20 LR = 60
. End of 2016 25 HR. 25 MR. 25 LR = 75
10.8 Thermal Treatment Progress:
One of the major targets in the plan was to reach 41% Thermal Treatment by 2013 and the policy under Chapter 15.6.
In order to support an integrated approach to waste management in the Region, after minimisation and recycling measures have taken place, residual waste shall be directed to thermal treatment in preference to landfill, in line with the EU waste hierarchy. Thermal treatment is an essential element to meet the landfill diversion targets included in the plan. It is estimated that a minimum thermal treatment capacity of 150,000 tpa will be required to meet the needs of the Region. This policy will encourage industry to substitute the use of fuels with alternative fuel sources.
The objectives in the plan are directed at private sector development of thermal treatment capacity in this Region or in adjacent Regions. The target for 2010 was as follows:-
In the event of the private sector not advancing the development of thermal treatment for the Region within the lifetime of this Plan, the Local Authorities shall engage with private industry to investigate its provision through a Public Private Partnership, or similar arrangement.
The private sector has shown interest in developing thermal treatment infrastructure in this Region over the past number of years. These technologies have all been alternate conversion type technologies with no proposals for mass burn incineration facilities. The types of conversion technologies of interest are listed below:
Page 113 Steam Classification(Autoclaving)
Advanced Pyrolysis and Pyrolysis with Gasification
Gasification Plants
Co-incineration of waste as a replacement fuel in the cement industry.
A pilot plant for steam classification/autoclaving was operating on permitted waste facility in Limerick over a number of months. Whilst the process seemed to be effective odiferous emissions from the plant were problematic. The pilot was not running long enough to see if the plant was an energy positive facility following the calculation of the parasitic loading of the plant.
Several pyrolysis plants were proposed by private sector consortia in the Region but none of these plants have adequate funding or suitable sites for development. Recently private sector companies have been interested in establishing a gasification plant for treatment of mainly municipal waste but would be combined with other high calorific value wastes. There is a preference to establish these facilities on existing authorized waste sites and some private sector funding appears be available.
Some progress has been made on communication with the private sector but there are currently no thermal treatment options available in the Region.
Recent Legislative Requirement.
As stated above the infrastructure within the Region operates either under either a waste license or CoR from the EPA or WFP from the relevant Local Authority, in accordance with the WMA 1996.
The principal legislative texts governing the form of authorisation required for waste facilities are:
Waste Management (Licensing) Regulations 2004 to 2011
Waste Management (Facility Permit & Registration) Regulations 2007, as amended
The EPA issue CoRs to Local Authorities for smaller scale waste activities listed in the Third Schedule Part II of the Waste Management (Facility Permit Registration) Regulations, S.I 821 of 2007 as amended.
The EC (Waste Directive) Regulations, 2011 adopted the waste hierarchy into Irish law with the infrastructure described above falling into the 3 lower ends of the 5 tiers namely recycling, recovery and disposal. The thermal treatment
Page 114 options mentioned earlier all fall into the energy recovery category except for the steam classification process which was undetermined at the end of the pilot operation.
Environmental Considerations:
The authorisations issued for the infrastructure detailed above have specific requirements in relation to environmental control measures and on-site monitoring. Notwithstanding these controls the developed infrastructure has potential to impact on the environment, for example:
Indiscriminate illegal dumping at bring banks
Generation of odours and leachate at MRFs, transfer stations and composting facilities
Generation of noise and hazardous leachate at ATFs
Generation of leachate, landfill gas and odour at landfills.
The above impacts, if not properly controlled may impact on groundwater & surface water quality as well as air quality.
Recommendation:
It is essential that all future County Development Plans within the Region allow for the development of the necessary waste infrastructure required to meet any new waste policy targets.
Since the publication of the plan authorised collectors within the Region have made significant progress in the roll-out of segregated commercial & household kerbside collection services, with 99% of householders now provided with a mixed dry recyclable collection service. The availability of this service negates the need for continual additional bring banks within the Region with the exception of glass bring banks as most collectors within the Region are not in a position to separately collect this waste fraction economically.
The significant roll-out of segregated collection services and private provision of CAS within the Region also negates the need for continual additional CAS, provided current sites are maintained with appropriate opening hours and continue to accept a wide variety of materials particularly items which cannot be accepted at the kerbside.
Although the number of ATFs in the Region has grown since 2006 there needs to be continued key policy objectives in relation to continued adequate
Page 115 establishment of treatment/recovery systems for all ELVs at no cost to the final holder. The current issues’ regarding the issuing of CoDs and illegal operators also needs to be addressed in any revised/replaced plan.
As the requirement for authorised collectors to provide a segregated organic waste collection service increases, the quantity of waste available for composting will also increase therefore any revised/replaced plan will require key objectives to encourage development of these facilities within the Region, in line with the proximity principle
The waste hierarchy is now established in European and Irish Law and therefore landfill disposal is bottom of the hierarchy and hence the least favoured option. Therefore the current over reliance on disposal of waste to landfill within the Region will have to be addressed in line with the EC (Waste Directive) Regulations, 2011 and recent Waste Policy. This will require on-going negotiations with private sector particularly in relation to thermal treatment processes and should be considered in any revised/replace plan.
The programme of risk assessment of closed landfills needs to continue and remediation procedures for each landfill need to be developed. Applications for Certificates of Authorisation will then be made as soon remediation funding is provided.
Future strategic waste planning needs to ensure that the cycle of under capacity followed by over-capacity of landfills is not repeated with the development of any future pre-treatment, recovery and/or disposal facilities.
Page 116 11.0 ENFORCEMENT & WASTE STATITCS The policies and targets relating to waste statistics and enforcement are included in Chapter 14.4.6 & 14.4.7 of the plan respectively with the following stated:
Chapter 14.4.6 Waste Statistics
Local Authorities will aim to improve data collection and reporting procedures through verification and auditing.
Chapter 14.4.7 Enforcement
Local Authorities, in conjunction with the OEE, will continue to enforce EU, national and local waste regulations and initiatives at both local and Regional levels.
Since the publication of the plan a significant number of additional waste regulations have been published with subsequent enforcement requirements. As a result of this the Region has undertaken significant measures in relation to the enforcement of waste regulations and collation of waste data and statistics.
Since 2007 the Local Authorities within this Region have being preparing RMCEI plans in accordance with the 2001 European Parliament and the Council adopted recommendation providing for minimum criteria for environmental inspections (RMCEI). The purpose of RMCEI is to strengthen compliance with, and to contribute to a more consistent implementation and enforcement of environmental legislation in all EU Member States. The RMCEI establishes criteria for environmental inspections of installations, other enterprises and facilities whose air emissions, water discharges or waste disposal or recovery activities are subject to authorisation, permit or licensing requirements.
Planning of inspection activities is a key requirement of the RMCEI. Planning is about defining and explaining as accurately as possible beforehand the work that is going to be undertaken so that it can be performed in an effective, efficient, transparent and accountable way.
The key requirements of the plan are as follows: -
Prepare a plan for environmental inspections;
Undertake inspections of relevant regulated facilities
Produce written reports of site inspections.
Copies of the annual RMCEI plans, prepared by the various Local Authorities within this Region, are submitted to the EPA on an annual basis for assessment.
Page 117 The EPA routinely audits the Local Authorities within this Region in relation to the implementation of these plans.
Assessing Implementation
Enforcement units have been established in all the Local Authorities in the Region but staffing levels and tasks vary considerably. A Regional enforcement task group was set up in 2005 to discuss planned and concerted enforcement action in the Region. The task group meets on a quarterly basis.
The focus of enforcement activities, within the Region, year-on-year is dependent on the perceived risk in the year ahead. For example, the priority over the last couple of years has been the closure of unauthorised ELV sites within the Region in order to ensure Ireland’s compliance with the European Court of Justice case ruling (ECJ C494/01) in relation to unauthorised ELV sites and implementation of the Food Waste Regulations (SI 508 of 2009).
In addition to the above, most enforcement officers spent considerable amounts of time on the following:-
WFP & CoR site audits
WCP audits
Inspection & auditing of unauthorised ELV Sites
Tyre outlet inspections
Packaging Inspections, in particular suspected major producers
Plastic bag levy
Waste Presentation Bye Laws
Table 11.1 below shows the enforcement activity trends within this Region over the last number of years:
Table 11.1 Enforcement Activity in the Limerick/Clare/Kerry Region 2006 - 2010 (Source RMCEI Review Data) TOTA TOTA TOTA TOTA L TOTAL L L L Question 2006 2007 2008 2009 2010 Total Complaints investigated 4,147 5,124 5,471 7,505 6,127 Routine Waste Inspection 253 455 384 464 1,127 Activities i.e.
Page 118 WFP/CoR/WCP/Vehicle Checkpoints Producer Responsibility Inspections i.e. WEEE/ELV/Farm Plastics/Plastic bag Levy/Packaging - 283 372 245 184 Waste Enforcement Actions i.e. Warning letters, S18, S55, S56 & S71 notices 570 712 997 645 818 Waste Prosecutions Initiated under WMA 1996 43 102 143 40 59
Table 11.1 shows the continued enforcement of waste regulations within the Region. However it should be noted that the slow process in bringing legal proceedings to a final stage can be quite cumbersome as it includes many steps as follows:-
- Issue Warning Letter
- Issue Enforcement Notice
- Commence Court Proceedings
- Court Hearing
- Court Decision
Accurate and up to date information on waste statistics is essential for monitoring progress with the implementation of waste legislation, waste management policies & waste management plans both at a Regional and National level.
In relation to waste data Local Authorities within the Region are responsible for collating, verifying and auditing the following data:
- WFP & CoR annual returns
- Records from CAS & bring banks
- Packaging self-complier data
The above details are then reported annually to the EPA via the Local Authority NWR. The EPA is currently examining the possibility of developing an on-line annual environmental report (AER) system for WFP and CoR sites, using a similar format to the WCP eAER system.
Page 119 The EPA provides annual training and guidance to Local Authorities in compiling the NWR, thereby improving data collection and reporting procedures. The EPA also carries out annual audits of a number of Local Authorities NWR and issues recommendations on proposed improvement measures. All Local Authorities in the Region have been audited by the EPA in the last four years.
The Local Authorities within this Region use various electronic complaints system for recording and managing waste and litter complaints. The systems are built on workflow and allow complaints to be assigned for investigation by relevant staff via the email system and facilitate the electronic storage of reports, correspondence and other documents. The systems are used as a proactive tool to manage waste-related complaints to ensure accurate and timely recording, appropriate communication with the public and satisfactory complaints resolution. The systems have proved very beneficial in tracking complaint statistics and generating user reports and queries. In addition to the above extensive paper-based and electronic records with regard to waste enforcement are also maintained by each Local Authority.
In addition to the electronic complaints tracking systems the Local Authorities within this Region have taken the following measures to improve data collection and reporting procedures:
Clare County Council carries out an annual programme of inspections and audits in relation to authorised waste collectors and waste facilities. The council generally employs a themed approach to waste collection auditing, reflecting waste enforcement priorities and issues that may arise. For example, the council focused on ELVs and waste tyres collectors in 2011, reflecting national and local waste enforcement priorities in that year. The council completes written reports for all inspections and audits of waste facilities, with particular attention paid to the assessment and verification of AERs from active authorised waste facilities in Co. Clare.
Kerry County Council’s waste enforcement staff carries out regular inspection and audits of the various authorised waste facilities in the County. As part of this process, periodic assessments of waste records and data are undertaken. In addition, joint WCP audits of a number of permitted collectors are carried out in conjunction with the RWMO. Spot-checks of AER information submitted are also carried out to assess accuracy.
As waste collection service providers (up to December 2011) Kerry County Council, along with the Town Councils in the County, put in place comprehensive in-house data collection and verification procedures in relation to waste collected by the Kerry Local Authorities.
Finally, as the body responsible for compiling and reporting waste statistics for the EPA’s Local Authority Questionnaire, which ultimately forms the basis of
Page 120 NWR, Kerry County Council carries out various checks and verifications while gathering and compiling the data in question.
Limerick County Council implement, through the RMCEI, an annual schedule of risk based audits of WCPs and WFPs with an aim to audit all WCPs based in the area and all WFPs. AER returns for WFPs are returned on a standard excel format, downloadable from the Local Authority web-site, as conditioned in the WFP. AERs received are reviewed by comparing them to previous year(s) submissions.
Limerick City Council audits all WFP AERs through reviewing on site records and recording systems. WCP holders based in the city are audited at least every 2 years where records and AERs are verified. All inspections carried under the different producer responsibility regulations (WEEE, Tyres, batteries, Packaging, ELVs, etc) include a full review of all waste records and verification against reports by compliance schemes. In November 2011 Limerick City Council carried out a full waste composition and quantitative survey of all waste collected by the City Council's cleansing fleet. The figures recorded in the survey were then compared against waste collection records supplied by the waste collectors for that week.
The RWMO, on behalf of the Local Authorities within the Region is responsible for collating, verifying and auditing the WCP data as well as collating all of the above other data in preparing the Annual Report on the plan.
Up until 2008 the WCP holders, permitted by this Region, submitted their AER on an excel file which then had to be collated and assessed. In 2008 the RWMO implemented a database system for the processing of WCPs which then facilitated the development of an on-line AER system (eAER) for the 2008 AER. Each collector was given a unique username and password and guidance on using the system. The selection options available to the permitted holder were linked directly to their WCP details hence they were only permitted to select the Local Authority area(s), EWC Codes and facilities as permitted by their WCP. The on-line return system significantly reduced errors made by the collectors and reduced administration burden on the RWMO, in collating numerous individual excel files which had its own associated error issues.
The on-line submission facilitated an ease of desk-top and on-site auditing of returns, which was not previously possible. A desk-top validation of each return could easily be facilitated including a comparison with previous year’s returns. The RWMO carries out on-site audits of all major household collectors and a selected number of large commercial collectors within the Region – a standard operating procedure (SOP) has been developed in relation to auditing of WCP AER returns.
Page 121 The downloading of the on-line AER returns onto the WCP database facilitated preparation of various AER reports, based on EWC Codes thereby allowing for more efficient analysis of data.
As a result of the success of the eAER system in this Region the WCP AER on-line return was implemented across all other Regions with assistance from the DECLG and EPA.
Recent Legislative Requirements:
Since the publication of the plan a number of additional waste regulations have been published including the following:
SI 126 of 2011 - European Communities (Waste Directive) Regulations 2011
SI 324 of 2011 - European Communities (Shipments of Hazardous Waste exclusively within Ireland) Regulations 2011
SI 434 of 2011 - Waste Management (Landfill Levy) Regulations 2011
SI 32 of 2010 Waste Management (Registration of Sewage Sludge Facility) Regulations 2010
SI 31 of 2010 - Waste Management (Landfill Levy)(Amendment) Regulations 2010
SI 13 of 2010 - Waste Management (Landfill Levy) Order 2010
S.I. No. 142/2010 — Waste Management (End-of-Life Vehicles) (Amendment) Regulations 2010
S.I. No. 143/2010 — Waste Management (Waste Electrical and Electronic Equipment) (Amendment) Regulations 2010
SI 508 of 2009 - Waste Management (Food Waste) Regulations 2009
Waste Management (Prohibition of Waste Disposal by Burning) Regulations 2009
SI 566 of 2009 - Waste Management (Management of Waste from Extractive Industries) Regulations 2009
Waste Management (Certification of Historic Unlicensed Waste Disposal & Recovery Activity) Regulations 2008.
Page 122 S.I. No. 86 of 2008 — Waste Management (Facility Permit and Registration) (Amendment) Regulations 2008
S.I. No. 87 of 2008 — Waste Management (Collection Permit) (Amendment) Regulations 2008
S.I. No. 268 of 2008 — Waste Management (Batteries and Accumulators) Regulations 2008
S.I. No. 66 of 2007 — Waste Management (Environmental Levy) (Plastic Bag) (Amendment) Regulations 2007
S.I. No. 664 of 2007 — Waste Management (Tyres and Waste Tyres) Regulations 2007
S.I. No. 798 of 2007 — Waste Management (Packaging) Regulations 2007
S.I. No. 820 of 2007 — Waste Management (Collection Permit) Regulations 2007
S.I. No. 821 of 2007 — Waste Management (Facility Permit and Registration) Regulations 2007
Regulation 6 of the European Communities (Waste Directive) Regulations 2011 amended Section 15 of the WMA 1996 by substituting the following paragraph for paragraph (b):
(b) (i) Establishments or undertakings which carry out waste treatment operations, establishments or undertakings which collect or transport waste on a professional basis, brokers and dealers, and establishments or undertakings which produce hazardous waste, shall be subject to appropriate periodic inspections by the local authorities, the Agency and Dublin City Council, as appropriate.
(ii) Inspections concerning collection and transport operations shall cover the origin, nature, quantity and destination of the waste collected and transported.
Therefore waste inspections carried out by Local Authorities are now a regulated specified requirement.
Since February 2012, all new and review WCP applications are being processed by the National Waste Collection Permit Office (NWCPO) based in Offaly County Council. In May 2012 the NWCPO took over the administration of all currently active WCP files for the Mid-West Region. As a result of the establishment of the NWCPO the national office shall now be responsible for the collation of the WCP AER data and the dissemination of the information to Local Authorities and/or Regions. The validation of the AER data will remain the responsibility of individual Local Authorities and/or Regions.
Page 123 The re-assignment of the Waste Regions shall influence the manner in which waste data is collated and assessed.
Assessment of Legislative Requirements:
The enforcement of all of the above Regulations adds significantly to the work load of the already stretched resources of waste enforcement teams.
A significant issue in the permitting process is the planning requirements that Local Authorities must examine as part of the application. This has proven to be quite difficult and cumbersome to examine.
In relation to collation and reporting of waste data a comprehensive electronic recording system is essential and the system used needs to be able to adapt to changing technology to ensure continuing efficiencies.
The collation and dissemination of WCP AER data by the NWCPO in a user friendly format shall be crucial to ensuring the verification and reporting system developed by this Region continues.
Environmental Considerations:
Failure to enforce the waste legislation shall result in non-compliance with legislative and plan targets. From an environmental perspective, there are possible implications for biodiversity, surface water and groundwater, air quality, climate, biodiversity and human health depending on the type and severity of the non-compliance.
At a local and Regional level, waste data provides annual feedback on the impact of Regional Waste Management Plans and can demonstrate the effectiveness of local waste initiatives. At a national level waste data delivers key indicators summarising the main issues to regulators, policy makers and decision makers. Waste data is also used to compile reports to the European Commission on the Waste Statistics Regulation (2150/2002/EC as amended) and also on implementation and to demonstrate compliance with diversion and recovery/recycling targets set in various Directives.
The complexity of the waste data requirements increases as each new waste reporting obligations are imposed.
Recommendation:
Continuous government funding is going to be essential to ensure the effectiveness of enforcement staff in the future. The current funding arrangement for Local Authority enforcement units remains in place until 2014.
Page 124 Continued funding beyond that date will be important in ensuring that gains made in the current plan are not lost and that the enforcement requirements of the new plan are acted on
The development of a standardised on-line reporting system for WFP & CoR AER returns would greatly improve data collection and reporting procedures within the Region. The collation and dissemination of WCP AER data by the NWCPO in a user friendly format shall be crucial to ensuring the verification and reporting system developed by this Region continues.
Irrespective of what system is used a comprehensive electronic recording system which is able to adapt to changing technology is essential for data collection & reporting to ensure continuing efficiencies. Future key policy objectives for waste statistics need to be more specific, measurable and reflect recent and proposed legislative changes and obligations in the area.
Page 125 12.0 SUMMARY
The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011 specified a number of targets, timeframes and indicators in relation to how the integrated approach to waste management in the L/C/K Region would be implemented over the timescale of the plan and these have been discussed in detail in the preceding Chapters of this document. Chapter 17 of the plan specified the implementation milestones, timeframes andprimary and secondary KPIs
The major milestones to be achieved within the period of the plan were specified and Table 12.1 below details current status of these milestones.
The timeframe for implementing the necessary infrastructure were specified and Table 12.2 below details the timeframe specified and indicates current status.
The primary and secondary performance indicators were set out in accordance with a recommendation of the Government policy statement ‘Taking Stock and Moving Forward’ and were chosen to reflect the main categories of waste in the plan. Tables 12.3 and 12.4 detail the primary and secondary KPIs specified and the subsequent progress over the lifetime of the plan. All annual reporting key performance indicators show significant progress in most areas over the plan period.
126Table 12.1 - Implementation Table (Min. Targets) specified in ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ & current status
YEAR
WASTE TOPIC 2005 2006 2007 2008 2009
Prevention Awareness initiatives on preventing and minimising of household waste at least twice per year Target achieved in all and Local Authorities Minimization Refer to Annual seminars & workshops on waste prevention for SMEs held annually Target achieved Chapters 4.1 & 4.4 for details Reuse and 1 Recyling Centre in 1 Reuse/Repair 1 Recycling Centre in 32 Bring Recycle Mungret and 1 in Centre for Region Co. Kerry – Killarney Banks Shannon Both (No Progress) (No Progress) provided (16 Refer to operational additional Chapters 10.1 All LA stationery to 1 Recycling Centre 1 Recycling Centre in banks & 10.2 for be purchased from in Limerick City South East Clare (No provided) details sustainable (No Progress) Progress)
Page 126 companies Not achieved 1 Recycling Centre 2 Recycling Centres in Co. Kerry – in Co. Kerry – Dingle Tralee (No (Operational) and Progress) Listowel (No Progress) Uncollected Standardise Survey of Waste the reporting Householders not Refer to methodology availing of a waste Chapter 5.1 Currently collection service for details being revised Achieved by EPA Collected Commence roll Finalise roll out of Waste out of organic organic collection Refer to collection service to Chapters 5.3 service to commercial and & 6.2 for commercial industrial details and industrial premises, and to premises households in Achieved towns over 1,000 population Achieved (42% of householders in the Region have a brown bin)
Table 12.1 (ctd.) - Implementation Table (Min. Targets) specified in ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ & current status
YEAR
WASTE 2005 2006 2007 2008 2009 TOPIC
Materials Recovery Monitor and report annually on performance of the MRF/Waste Transfer stations in the Region – Within this Region all Refer to these facilities are currently privately operated and regulated via EPA Licence or WFP issued by the relevant Chapter 10.3 Local Authority, therefore monitoring of the facilities is undertaken by the relevant authorisation authority. for details C & D Refer to LAs to work with industry to provide C&D Recycling facilities as appropriate for the Region – Four privately operated C&D Chapter 8.0 recycling facilities became operational during the plan period. for details Hazardous Waste One Public education campaign per year on household Refer to hazardous waste 2 campaigns undertaken. Chapter 9.1 for details One education campaign per year on SME hazardous waste 3 campaigns undertaken
Packaging 50-65% by Refer to weight Chapter 6.1 recovered. 25- for details 45%of this recycled
Page 127 Achieved WEEE All major Recycling Refer to Centres to accept Chapter 9.2 WEEE Achieved for details Explore alternative WEEE collection options for householders – Annual ERP open days & ‘Be Free Recycling’ events Waste Statistics To Develop Audit Programmes to verify data and conduct Annual Audits – Achieved Refer to Chapter 11.0 for details
Page 128 Table 12.2 - Infrastructure Timetable specified in ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ & Current Status
Infrastructure Public Private PPP Timetable for Procurement Bring Banks - Refer to 32 additional bring banks provided Yes - - Chapter 10.1 for details throughout the Region by 2009 8 additionaladditional sites banks by 2010 provided) (must accept Recycling Centres - Refer to Possibl Household Hazardous waste, WEEE and Yes Possible Chapter 10.2 for details e Green Waste) 6 additional sites opened & all accept above waste types Green Waste Collection- Refer Possibl All major Recycling Centres to accept Yes Yes to Chapter 10.2 for details e green waste by 2010 - Achieved 2 Additional facilities for the Region by Biological Treatment Yes Yes Yes 2007 – Currently 4 operational Thermal Treatment Facility - Commence procurementfacilities. within Plan period Possibl Refer to Chapter 10.8 for No Possible – Not achieved, however private e details sector has shown interest. Additional phases as required – Municipal Landfill - Refer to Yes Possible - that the two remaining landfills will Chapter 10.6 for details cease to accept waste by mid to end Construction/Demolition Recycling facilities 2013provided for the Region Possibl Recycling - Refer to Chapter Yes Yes by 2007 – Four privately operated C&D e 8.0 for details recycling facilities became WEEE - Refer to Chapter 9.2 operationalAll major Recycling during Centresthe plan to period3accept Yes Yes - for details WEEE by 2006 - Achieved Trial Reuse/Repair Yes Possible Possibl One centre for the Region by 2007 e achieved
Table 12.3 - Summary of ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ annual primary KPIs outcomes 2006-2010. Area Primary Indicator 2004 2006 2007 2008 (Baselin e) 424kgs Household Household waste generated per - 384kgs 367kgs 371kgs Prevention capita (kgs) - - 340kgs Household waste managed per capita (kgs)
Page 129 (Note: The 2009 & 2010 figures are based on the 2011 Census) 1,246kg Commercial & C&I Waste generated per Employee s 1,092kg 1,165k 1,010k Industrial (kgs) s gs gs Prevention
Household Reuse No of reuse/repair centres N/A 1(temp) 0 0 % of household waste recycled Household (Managed) 18% 30% 31% 33% Recycling C&I Recycling Rate Commercial & 56.9% 64% 65% 61% Industrial Recycling % of packaging waste recycled
Packaging Waste 48% Data not 50% 48% available
Uncollected Waste Quantity of uncollected household 39,618t 35,233t 17,440t 16,949t waste
(Note: The 2009 & 2010 figures are based on the 2011 Census)
C& D Waste % C&D waste recycled Data not Data not Data 50% available not available availabl e WEEE National Target (kgs/head) 4 6.7 7.2 9.8 Landfill Disposal % of municipal waste landfilled 37% 44% 50% 48%
% of municipal waste recycled Municipal Waste (Managed) (Note: The 2009 & 2010 figures are based on the 2011 Census) Note: The following primary indicators were also specified in the plan but as they were immeasurable they have not been included in the above table: % Biowaste recovered from the mixed municipal waste stream; tones household hazardous waste collected & Megawatts of electricity.
Page 130 Table 12.4 - Summary of ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ annual secondary KPIs outcomes 2006-2010. Area Secondary Indicator 200 2006 200 200 200 20 4 7 8 9 10 (Ba seli ne) 14,0 Househol - No. of compost bins 00 - - - 15,6 15, d (cumulative year to year) 72 46 859 Preventio - 117 198 224 n - No. of green flags 257 283 (cumulative year to year) 18 43 74 96 123 - No. of awareness events(cumulative year to year) 120 Commerci - No. of site visits 175 190 232 259 308 al & (cumulative year to year) Industrial Preventio n
Househol - No. of bring banks 215 226 226 224 228 231 d Recycling - No. of Recycling Centres 13 15 16 16 16 16
- No. of households with Not 90,2 88,9 91,9 92,6 93, source separated avail 59 19 63 33 372 collections able % of waste collected in Commerci source separated 30% 38.0 39. al & collections % 7% Industrial Recycling -No. of biological Biological treatment facilities 0 1 1 2 3 4 Treatment -Tonnes of organic waste (brown bin) collected 0 0 0 340 3,35 5,8 - Estimated tonnes of 8 01 home compost generated - 3,60 2,89 2,92
Page 131 6 6 5 3,84 3,4 9 46
C&D -No. of C/D processing 0 0 1 4 5 5 Waste facilities WEEE - No. of collection events - - - 33 30 30 - No. of Repak members Packaging 134 - - - - Waste
Landfill - % of BMW landfilled - - - - - 59. Disposal (based on EPA BMW 53 factors) %
Note: The following secondary indicators were also specified in the plan but as they were immeasurable they have not been included in the above table: Composition surveys; Inventory of items reused; No. of recycling parks; Hazardous Waste Collection Events, Tonnes of green waste collected; Tonnes of crushed C&D aggregate reused; Packaging Waste- Composition survey - Dry Recyclables; Landfill Disposal - Composition Survey
13.0 OVERALL RECOMMENDATION Recently published DECLG documents, “Waste Management Policy in Ireland –A Resource Opportunity” (July 2012) and “Action Programme for Effective Local Government-Putting People First” (October 2012) indicated the reduction in the number of waste plan regions to a maximum of three in line with the Regional Assemblies As a result of this reform this Region will be joining with other Local Authorities and it will then be necessary to prepare a new Waste Plan for the new Region. Following the evaluation of The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011 it is recommended that the current plan policies needs to be revised/replaced in order to reflect the legislative and policy changes since the publication of the plan in 2006. A summary of the policies under the current plan are listed in Table 13.1 below along with a recommendation on whether the specific policy needs to be revised/replaced or no change required. As can be seen from Table 13.1 almost all of the current policies need to be revised/replaced.
The new plan should have clear policies on the following aspects, with specific measurable objectives specified:
Page 132 Prevention/Re-use Recycling
Organic Waste
Household Waste Collection
Commercial Waste
Priority Waste
Infrastructure
The evaluation process recommends that the following are incorporated under the policies listed above:
Prevention/Re-use
o The waste prevention programmes currently in place need to be continued as well as establishing additional programmes in line with the EC (Waste Directive) Regulations, 2011
o There is a clear need to have standard qualitative and quantitative benchmarks for waste prevention in order to monitor progress. (Under the EC (Waste Directive) Regulations, 2011 the determination of these benchmarks is the responsibility of the Agency).
o The dedicated role of RIWMO(s), prevention officer and the EAOs are key in delivering the prevention objectives of future plans
Recycling
o In order to meet the EC (Waste Directive) Regulations 2011 requirement for a household recycling rate of 50% by 2020 there is a need for a clear policy on recycling which targets both kerbside collection and subsequent treatment. The household charging mechanism also needs to be an effective tool in increasing recycling rates.
o Waste composition studies carried out on behalf of the EPA and investigations within this Region reveal the residual commercial waste still contains high level of materials for recycling and recovery. Therefore a policy needs to be introduced to ensure that collectors provide mixed recycling bin to all commercial premises and that these bins are used appropriately by the premises through the enforcement of existing legislation.
Organic Waste
Page 133 o Objectives on organic waste collection and disposal need to be included in line with the recent Waste Management (Food Waste) Regulations 2009, Waste Management Policy (July 2012) and any future associated Regulations. Future key policy objectives for organic waste need to be specific, measurable and reflect recent legislative changes in the area, particularly in relation to enforcement of both the authorised collectors and the producers of the waste.
o The requirement for further/continuing education of waste producers needs to be recognized and developed in order to achieve an improvement in the quality of brown bin waste as a means to finding more sustainable outlets for the stabilized end product.
Household Waste Collection
o More specific and measurable key policy objectives need to be included for household waste collection and segregation to reflect recent legislative changes in the area. A KPI for number of households signed up to a service should also be included.
o As the current pay-by-use WCP condition has proven very difficult to enforce, consideration should be given to a move away from a pay by use system towards a specific pay by weight system to counteract the ‘Flat Charge’ type marketing.
o Due to the recent roll-out of privately operated PTU’s within the Region the role of these units, along with a clear policy on their use, needs to be included.
o In order to identify appropriate measures (awareness and/or enforcement) to reduce the percentage of uncollected waste and associated illegal dumping within the Region the household waste collection survey carried out in the Region in 2006 needs to updated in order to obtain a current, accurate picture of what is happening on the ground. Also the methodology used to calculate the amount of uncollected waste within the Region needs to take account of the EPA’s proposed amended methodology
o It would be extremely beneficial to have a statistically valid survey of household waste management behaviours (e.g. use of kerbside collection services versus bring centres, home composting information etc.) i.e. via CSO Quarterly National Household Survey
Commercial Waste
Page 134 o More specific and measurable key policy objectives need to be included in relation to commercial waste generation i.e. prevention, adequate source segregation and appropriate collection.
o Insufficient waste storage capacity particularly in city/town centre commercial areas needs to be addressed via Local Authority Development Plans and Local Area Plans. Cognisance should be given to the Northern Ireland guidance document ‘Local Government Waste Storage Guide for Northern Ireland’, until such time as an Irish national guidance document in relation to storage capacity requirements is developed.
Priority Wastes
o The policy objectives for priority wastes need to include the following waste streams:
- C&D waste
- Hazardous waste
- WEEE
- ELVs
- Tyres
Prevention initiatives and clear objectives and targets on segregation at source of the above waste streams need to be specified. Specific and measurable key policy objectives will also be required in relation to the enforcement of relevant legalisation, particularly in relation to unauthorised activities and producer responsibility initiatives.
As sludge waste management plans do not require a public consultation phase a decision on whether they need to be included in future waste plans needs to be ascertained.
Infrastructure
o The County Development Plans within the Region need to allow for the development of the necessary waste infrastructure required to meet any new waste policy targets. o The policy needs to reflect the changes in collection practices over the life time of the current plan i.e. significant roll-out of segregated commercial & household kerbside collection services. Therefore the policy needs to ensure current CAS are maintained with appropriate opening hours and
Page 135 they continue to accept a wide variety of materials particularly items which cannot be accepted at the kerbside. Consideration needs to be given to the adequacy of our current bring bank network. o Although the number of ATFs in the Region has grown since 2006 there needs to be continued key policy objectives in relation to continued adequate establishment of treatment/recovery systems for all ELVs at no cost to the final holder. The current producer responsibility initiative needs to be reviewed if Ireland is to meet the current EU re-use and recovery targets for ELVs. o As the requirement for authorised collectors to provide a segregated organic waste collection service increases, the quantity of waste available for composting shall also increase therefore key objectives to encourage development of these facilities within the Region, in line with the proximity principle is required. o The waste hierarchy is now established in European and Irish Law and landfill disposal is bottom of the hierarchy and hence the least favoured option. Therefore the current over reliance on disposal of waste to landfill within the Region shall have to be addressed in line with the EC (Waste Directive) Regulations, 2011 and recent Waste Policy. There will be no landfill void space available within the Region at current filling rates by the end of 2013 and therefore exploring alternative disposal options must be a priority in 2013. This will require on-going negotiations with the private sector particularly in relation to thermal treatment processes. o The programme of risk assessment of closed landfills needs to continue and remediation procedures for each landfill need to be developed. Applications for Certificates of Authorisation will then be made in line with the DECLG roadmap for certification. o Future strategic waste planning needs to ensure that the cycle of under capacity followed by over-capacity of landfills is not repeated with the development of any future pre-treatment, recovery and/or disposal facilities
In order to ensure the effective implementation of any new plan continuous government funding of prevention/awareness and enforcement staff will be essential. The polluter pays principle must be incorporated into all waste management activities going forward.
It will also be important to ensure existing forums for Local Authority staff to network, share and discuss potential efficiencies are continued and enhanced and that emerging social media is embraced to its maximum benefit.
Page 136 Table 13.1 - Summary of the policies listed in The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006- 2011 Chap Policy Revis ter e/Rep lace Waste Prevention and Minimisation 14.4. √ Waste Management Policy will prioritise waste prevention and minimisation at 1 source as a key strategy component focusing on delivering more tangible success in waste reduction. This will be focused at industrial, commercial and household level and will take account of new initiatives in this area such as the establishment of a National Waste Prevention Programme and assisted by the Race Against Waste awareness Campaign. √ The policy will focus on furthering awareness objectives on waste 15.2 management, targeting schools, householders, industry, resident associations, community groups, etc.
The Local Authorities will commit to prioritising waste prevention and minimisation as outlined in the EU and Irish Waste hierarchy. 14.4. Waste Collection 2 √ Waste collection policy will be centred on the expansion of collection services to maximise coverage throughout the Region and to extend a three-bin system for settlements greater than 1000 population. Pay by Weight/Use shall be fully implemented throughout the Region.
Waste Reuse and Recycling 14.4. √ The policy shall focus on encouraging and regulating householders and the 3 private sector to maximise reuse and recycling in the Region. 15.3. Local Authorities shall promote reuse and recycling at all levels to achieve √ 1 Regional targets in conjunction with the EU hierarchy. Local Authorities will continue to promote the kerbside collection of dry recyclables. 15.3. √ 2 The Local Authorities shall adopt an environmental management approach within their organisations to address waste prevention, green procurement 15.3. and recycling. 3 The Local Authorities will assist in raising awareness of the reuse and recycling opportunities in the industrial and commercial sector in order to reach the Regional targets. 14.4. Thermal Treatment
Page 137 4 This Policy will focus on the provision of thermal treatment to recover energy √ from the residual waste body remaining after preferred treatment options. 14.4. Waste Disposal √ 5 Waste Disposal Policy shall consider the medium to long-term options for rationalisation of landfills in the Region, taking account of residual capacities and timetables for alternative treatment options. 14.4. Waste Statistics √ 6 Local Authorities will aim to improve data collection and reporting procedures through verification and auditing
14.4. Enforcement 7 Local Authorities, in conjunction with the OEE, will continue to enforce EU, national and local waste regulations and initiatives at both local and Regional levels.
14.4. Priority Waste Streams √ 8 Specific policy recommendations are directed towards priority wastes as identified through the EU Directives and National Objectives.
14.5 Targets: √ The proposed policy prioritises prevention as a key focus area for the duration of this new plan, the remaining targets to be reached by 2013 for each treatment option are detailed below: Recycling 45% Thermal Treatment 41% Disposal 14% 15.4 Uncollected Waste: √ The Local Authorities shall endeavour to determine the extent of uncollected waste in the Region and to eliminate ‘Environmentally Unfriendly Practices’ relating to the collection disposal of household waste.
Organic Waste: 15.5 The Local Authorities shall endeavour to meet the targets outlined in the National √ Strategy on Biodegradable Waste. 15.5. √ To reduce the quantity of biodegradable waste landfilled in accordance with 1 the EU landfill Directive. An integrated approach to waste management will
Page 138 require treatment technologies such as Mechanical Biological Treatment (MBT) in order to reach the 2010 and 2013 landfill diversion target and to meet the 2010 target set out in the National Biowaste Strategy. 15.6 Thermal Treatment √ In order to support an integrated approach to waste management in the Region, after minimisation and recycling measures have taken place, residual waste shall be directed to thermal treatment in preference to landfill, in line with the EU waste hierarchy. Thermal treatment is an essential element to meet the landfill diversion targets included in the plan. It is estimated that a minimum thermal treatment capacity of 150,000 tpa will be required to meet the needs of the Region. This policy will encourage industry to substitute the use of fuels with alternative fuel sources. 15.7 Materials Recovery Facilities/ Waste Transfer Stations √ The Local Authorities will support the development of additional MRF and Waste Transfer facilities where these can be shown to be consistent with the overall objectives of the Plan. 15.8 Landfill Disposal √ Landfills will be developed and operated to the highest international standards in accordance with Waste Licenses issued by the EPA. To ensure that there is adequate landfill capacity in the Region.
15.9 Closed landfills √ The Local Authorities will have regard to Article 22(7)(h) of the WMA 1996, the Section 60 guidance as issued by the Minister on 3rd May 2005 and, when published, the EPA Code of Practice regarding the investigation of former waste disposal/recovery sites in the Region. 15.10 Former Hazardous Waste Disposal Sites The Local Authorities will ensure that their obligations under the National Hazardous Waste Management Plan are fulfilled regarding former hazardous waste disposal sites in the Region. 15.11 Inter-Regional Movement of Waste While it is recognised that there should be flexibility with respect to the movement of waste across Regional boundaries, account must be taken of the proximity principle and sustainable environmental principles. 15.12 Directing Waste to Meet Plan Objectives The Local Authorities need to ensure that the Plan objectives are met and that waste when privately collected is delivered to the form of treatment intended
Page 139 in this Plan. The Local Authorities for environmental or other reasons will if necessary and/or appropriate direct that certain waste streams must be delivered to a certain tier in the waste hierarchy (e.g. reuse, recycling, biological treatment, energy recovery facility). This will be achieved by means of the waste collection permit system or other appropriate regulatory or enforcement measures Construction and Demolition Waste 16.1 √ To reduce the generation of C&D waste and ensure that reuse and recycling of this waste is maximised in support of the Implementation Plan for the Management of C&D Waste in the Region. 16.2 Hazardous Waste To ensure that hazardous waste management is addressed through an integrated approach of prevention, recycling, treatment and disposal.
16.3 Waste Electrical and Electronic Equipment (WEEE) √ The Local Authorities shall maximise the collection, reuse and recycling opportunities for all WEEE in the Region to meet the requirements of WEEE Regulations (SI 340 of 2005) 16.4 End of Life Vehicles √ To ensure that ELVs are dismantled and recovered in a manner which does not cause environmental pollution and ensure that the recycling and recovery rates of ELVs and their components are met. 16.5 Tyres √ To minimise the illegal disposal of waste tyres and increase the quantity of tyre recycling.
16.6 Sludge √ To implement the policies as stated in each Sludge Management Plan.
Page 140 APPENDIX A
Page 141 Evaluation of Regional Waste Plans Waste Legislation Document
July 2012 Prepared by RPS
Page 142 Table of Contents
LIST OF TABLES:...... 1 LIST OF FIGURES:...... 2 ABBREVIATIONS:...... 3 EXECUTIVE SUMMARY...... 4 1.0 INTRODUCTION...... 6 2.0 LEGISLATIVE UPDATE...... 7 3.1Targets...... 8 3.2 Inter-Regional Movements of Waste...... 8 3.3 Cost Recovery...... 8 4.0 WASTE PREVENTION...... 10 4.1 Waste Prevention Community/Household Level:...... 10 Fig 4.1 Household Waste Management & Generated per captia L/C/K REGION 2008-2010...... 11 Fig 4.2 Household Waste Managed- Regional comparison 2010...... 11 Table 4.2: Newspaper weekly circulation rate...... 11 Table 4.3: Radio Listenership...... 11 4.2 Waste Prevention –Home Composting...... 11 Table 4.4: Estimated quantity of Home Composted Waste, within the Region, 2005- 2011 (tonnes)...... 12 4.3 Waste Prevention at Schools Level...... 12 Fig. 4.3 No of schools with green flag...... 12 Table 4.5 No of Registered Green Schools, active Green Flags/annum and number of students influenced by programme...... 12 4.4 Waste Prevention in the Commercial/Industry Sector...... 12 Table 4.6: RIWMO Involvement in Commercial/Business/Industry Events..13 Table 4.7: EAO Involvement in Business Events...... 13 4.5 Reuse at Business and Industry Level...... 13 4.6 Working with National Initiatives...... 13 Table 4.8: 2010 LAPN Programme - Events/Tourism/Sport Details...... 15 Table 4.9: 2010 LAPN Programme - Health Care Details...... 15 Table 4.10: 2010 LAPN Programme - In House Resource Efficiency Details 15 Table 4.11: 2010 LAPN Programme - Food Waste Prevention Details...... 15 Table 4.12: 2010 LAPN Programme - Networks for Waste Prevention...... 16 Table 4.13: 2011 LAPN Programme - Limerick City:...... 16 Table 4.14: 2011 LAPN Programme - Limerick County:...... 16 Table 4.15: 2011 LAPN Programme - Clare County:...... 16
Page 143 Table 4.16: 2011 LAPN Programme - Kerry County:...... 16 Table 4.17: 2011 LAPN Programme - Additional Projects:...... 16 Table 4.18: 2012 LAPN Programme - Current Projects:...... 17 5.0 HOUSEHOLD WASTE MANAGEMENT...... 19 5.1 Waste Collection/Uncollected Waste...... 19 Table 5.1 No of Households signed up to a service...... 19 Table 5.2 Percentage of Households signed up to a service...... 19 Table 5.3 Tonnage of uncollected waste:...... 20 Table 5.4 Total Complaints and Litter Complaints in the Region...... 20 5.2 Re-use and Recycling...... 21 Fig. 5.1 Regional Household Recycling Rate Comparison...... 21 5.3 Organic Waste Collection...... 21 Fig. 5.2 Quantity of source segregated household biodegradable waste collected within the Region 2008-2011...... 22 ...... 22 5.4 Bring Banks...... 22 Table 5.5 Tonnage of Waste Collected at Bring Banks in L/C/K Region 2006 - 2010...... 22 5.5 Recycling Centres/Civic Amenity Sites/Transfer Stations...... 22 Table 5.6 Tonnage of Waste Collected at Recycling Centres in L/C/K Region 2006 - 2010...... 22 Fig. 5.3 Regional Recycling Rate Comparison...... 23 6.0 COMMERCIAL WASTE MANAGEMENT...... 24 6.1 Commercial and Industrial Waste Generation and Recycling...... 24 Fig. 6.1 Commercial and Industrial waste arisings per annum...... 24 Fig. 6.2 Commercial and Industrial waste arisings per Employee...... 24 Fig. 6.3 Commercial and industrial waste percentage recycling...... 24 6.2 Commercial Organic Waste...... 24 Table 6.1 Tonnes of Source Segregated Commercial Organic Waste collected in the Region since 2008...... 25 Fig 6.4 Commercial Organic Waste collected within the Region 2008-2011 ...... 25 7.0 MUNICIPAL WASTE INCLUDING BIODEGRADABLE MUNICIPAL WASTE...... 26 Table 7.1 Municipal Waste Generated...... 26 7.1 Biodegradable Municipal Waste...... 26 8.0 CONSTRUCTION AND DEMOLITION WASTE MANAGEMENT...... 28 Fig 8.1 C&D Waste arisings within the Region 2004-2011...... 28 9.0 OTHER PRIORITY WASTE STREAMS...... 30 9.1 Hazardous Waste...... 30 Table 9.1 Breakdown of Quantity of Hazardous Waste Collected in Region 2008-2010...... 30 9.2 Waste Electronic and Electrical Equipment (WEEE)...... 31 Table 9.2 Quantity of WEEE Collected in Region 2008-2010...... 32
Page 144 Table 9.3: WEEE Inspections in the L/C/K Region in 2010 (Source RMCEI Review Data)...... 32 9.3 End of Life Vehicles(ELVs)...... 32 Table 9.4: Quantity of ELVs collected within the Region for the period 2008 – 2011...... 33 Table 9.5: ELV Inspections in the L/C/K Region 2007- 2010 (Source RMCEI Review Data)...... 33 9.4 Tyres...... 34 Table 9.6: Quantity of Tyres collected within the Region for the period 2008 – 2011...... 34 Table 9.7: Tyre Inspections in the L/C/K Region in 2009-2010 (Source RMCEI Review Data)...... 34 9.5 Sludges...... 35 Table 9.8: Quantity of Sludge collected within the Region for the period 2008 – 2011...... 35 10.0 INFRASTRUCTURE...... 37 10.1 Bring Banks...... 37 Table 10.1 Bring Bank (BB) Numbers...... 38 10.2 Recycling Centres/Civic Amenity Sites/Transfer Stations:...... 38 Table 10.2 Recycling Centre Targets...... 38 10.3 Material Recovery Facilities (MRFs) and transfer stations:...... 39 Table 10.3 Waste Facility & Licence/Permit Processing Limit...... 39 10.4 Authorised Treatment Facilities (ATFs)...... 40 Table 10.4: ATFs in the L/C/K Region...... 41 Table 10.5 Current permitted processing capacity within the L/C/K Region41 10.5 Composting facilities:...... 41 10.6 Landfills:...... 41 Table 10.6 Remaining Landfill capacity Limerick/Clare/Kerry Region (October 2012)...... 41 10.7 Historic Closed Landfills:...... 42 10.8 Thermal Treatment Progress:...... 42 11.0 ENFORCEMENT & WASTE STATITCS...... 45 Table 11.1 Enforcement Activity in the Limerick/Clare/Kerry Region 2006 - 2010 (Source RMCEI Review Data)...... 45 12.0 SUMMARY...... 49 0Table 12.1 - Implementation Table (Min. Targets) specified in ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ & current status...... 49 Table 12.2 - Infrastructure Timetable specified in ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ & Current Status...... 50 Table 12.3 - Summary of ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ annual primary KPIs outcomes 2006-2010...... 50
Page 145 Table 12.4 - Summary of ‘The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011’ annual secondary KPIs outcomes 2006-2010...... 50 13.0 OVERALL RECOMMENDATION...... 51 Table 13.1 - Summary of the policies listed in The Replacement Waste Management Plan for the Limerick/Clare/Kerry Region 2006-2011...... 52 APPENDIX A...... 57 APPENDIX B...... 70 Table B1 Details of NIPP outcomes 2006-Sept 2009...... 71 Table B2: Key Performance Indicator Details NIPP 2006-2008...... 71 Table B3: Fostering Sustainable Behaviour Details...... 71 APPENDIX C...... 71 Table C1: Closed Landfill Draft Register Limerick/Clare/Kerry Region...... 72
Introduction 146
Under the transposing regulations (S.I. 126 of 2011) of the Waste Framework Directive (2008/98/EC) there is a requirement to evaluate existing waste management plans by 31 December 2012 and, consequent to such an evaluation, to revise plans as appropriate. In 2011 the Department of the Environment, Community and Local Government (hereafter the Department) established a National Coordination Committee to assist local authorities and the wider waste Regions with the evaluation process.
The National Coordination Committee’s membership includes nominees from each Waste Management Region, in addition to representatives of the EPA and the Department. The work of the National Coordination Committee aims to facilitate a cost-effective and efficient evaluation of waste management plans by local authorities through the provision of supporting documents, presentations, waste data and technical guidance to committee members.
This Waste Legislation Document has been prepared through the work of the committee for the sole purpose of assisting local authorities in respect of the evaluation process. The document contains a non-exhaustive list of key waste regulations which has been introduced since the making of the previous Regional waste management plans. The waste regulations identified are considered to be the most relevant in terms of the evaluation process and the subsequent waste plan review process.
The document contains a summary of each regulation along with selected extracts which identify key Local Authority requirements. During the evaluation of a waste management plan it will be necessary for local authorities to consider specific waste plan objectives in the context of those waste regulations which have come into force since the publication of the
Page 146 Regional waste management plans. A Local Authority should examine policy objectives against the regulatory requirements, decide whether a particular policy objective is adequate or whether it needs to be revised or replaced. This decision making process at the policy objective level will help to inform the evaluation process and the final collective decision to revise or replace the Regional waste management plan.
Page 147 S.I. No. 282/2006 — Waste Management (End-Of-Life Vehicles) Regulations 2006
SI Summary
These Regulations are designed to implement the provisions of Directive 2000/53/EC of the European Parliament and of the Council on end-of-life vehicles. They are intended to facilitate the achievement of the -
85% reuse/recovery with 80% reuse/recycling by average weight per vehicle and year, on and from the date of commencement of the Regulations, and
95% reuse/recovery with 85% reuse/recycling by average weight per vehicle and year, by the 1 of January 2015.
The Regulations place obligations on each producer (a producer in relation to a vehicle, means the person who imports into, or manufactures in, the State the vehicle) to establish a national collection system for the collection of specified vehicles, of that producer's brand or for which that producer has responsibility, which that producer anticipates will become end-of-life vehicles in the State and will require appropriate treatment and recovery. Each producer's national collection system will comprise of at least one authorised treatment facility in the functional area of each Local Authority and must have sufficient capacity to treat the number of end-of-life vehicles, of that producer's brand or for which that producer is responsible, that arise in any given year.
An authorised treatment facility in a producer's national collection system must be reasonably accessible to any person who wishes to deposit an end- of-life vehicle to that facility and where that vehicle is accepted for appropriate treatment and recovery no charge shall be imposed on the registered owner of that vehicle except in cases where the vehicle's essential components are missing or waste has been added to that vehicle. This applies from 1 November 2006 to vehicles placed on the market on or after 1 July 2002 and to all vehicles from 1 January 2007. Each producer shall be required to register with each Local Authority and to provide specified information to the local authorities to accompany their registration.
In Part IV of the Regulations, obligations are imposed on producers to ensure that the materials and components of vehicles do not contain lead, mercury, cadmium or hexavalent chromium other than in cases specified in the Fourth Schedule and that technical documentation must be made available by the producer to verify compliance with these requirements.
Obligations are imposed on authorised treatment facilities to ensure that such facilities operate under a waste license, or as appropriate, a waste permit and meet the minimum technical requirements for the -
Page 148 (i) storage (including temporary storage) of end-of-life vehicles prior to their being the subject of appropriate treatment and recovery, (ii) appropriate treatment and recovery of end-of-life vehicles, (iii) storage of components containing fluids, recoverable components and spare parts.
An authorised treatment facility shall be required to keep specified records in relation to the appropriate treatment and recovery of end-of-life vehicles and report to a producer, if that facility forms a part of a producer's national collection system, or to a Local Authority, if that facility does not form a part of a producer's national collection system.
From the 1 January 2007, on the deposit of an end of life vehicle at an authorised treatment facility for appropriate treatment and recovery, the owner or operator of that facility shall issue a certificate of destruction to the registered owner, an authorised person of a Local Authority or a member of An Garda Síochána and all relevant information relating to that certificate of destruction shall be noted on the national vehicle records.
Amendment SI:
S.I. No. 142/2010 — Waste Management (End-of-Life Vehicles) (Amendment) Regulations 2010
These Regulations amend the Waste Management (End-of-Life Vehicles) Regulations 2006 and are intended to give effect to Article 4 of Directive 2008/112/EC
For the avoidance of doubt, Article 4 of Directive 2008/112/EC amends the meaning of hazardous substances as set out in Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of-life vehicles in accordance with requirements under the globally harmonised system (GHS) on the classification and labelling of chemicals which have been incorporated into Regulation (EC) No. 1272/2008 of 16 December 2008.
The Regulations also appoint the Environmental Protection Agency as the competent authority for the enforcement of Part IV of the Waste Management (End-of-Life Vehicles) Regulations 2006 and clarify that the Part IV obligations on producers also apply to persons involved in the sale, supply or use in the State of materials and components in respect of specified vehicles.
SI 282/2006 Selected Requirements for Local Authorities
Enforcement
Section 33. (1) Subject to sub-article (2), each Local Authority shall be responsible for the enforcement of Parts II and III and articles 35 and 36 of these Regulations within their functional areas and shall take such steps as are necessary for this purpose.
(2) Where an authorised treatment facility operates under a waste licence in accordance with the provisions of section 39 of the Act and any
Page 149 Regulations made thereunder, the Agency shall be responsible for the enforcement of articles 13 to 16 inclusive, the Second Schedule to these Regulations and Part III of these Regulations in respect of that authorised treatment facility and shall take such steps as are necessary for this purpose.
(3) The competent authority prescribed by the Minister under the provisions of article 28(3) shall be responsible for the enforcement of Part IV of these Regulations within the State and shall take such steps as are necessary for this purpose.
Power of a Local Authority to require Submission of Information and issue Written Directions
Section 34. (1) A Local Authority may, by notice in writing, require a producer to furnish, within a specified period of not more than six weeks, such further information or particulars as may be specified in the notice regarding a producer's -
(a) application for registration, or as appropriate, (b) application for renewal of registration, for the purpose of complying with the provisions of article 12(4)(b).
(2) A Local Authority may, by notice in writing, require a producer to make, within a specified period of not more than six weeks and taking account of any directions as may be specified in the notice, a new application -
(a) for registration, or as appropriate, (b) for renewal of registration, for the purpose of complying with the provisions of article 12(7).
S.I. No. 664/2007 — Waste Management (Tyres and Waste Tyres) Regulations 2007
SI Summary
The Regulations impose obligations on persons who supply tyres to the Irish market, whether as retailers, importers or manufacturers and on persons who manage waste tyres. These Regulations are designed to maximise the reuse, recycling and recovery of waste tyres.
The Regulations require producers, suppliers and authorised waste collectors to provide specified information to local authorities. The Regulations were enacted to improve information gathering and the tracking of waste tyre flows within Ireland. Suppliers of tyres to the Irish Market, whether manufacturers, wholesalers, suppliers, traders, or retailers or collectors of waste tyres who do not participate in a voluntary compliance scheme must register annually with the relevant Local Authority, and pay annual registration and re-registration fees.
Page 150 Detailed reporting on quantities of tyres placed on the market or collected must be made to the relevant Local Authority. In accordance with the Regulations anyone who wishes to collect tyres must hold a valid Waste Collection Permit in order to be classified as an Authorised Waste Collector.
SI 664/2007 Selected Requirements for Local Authorities
Enforcement
Section 31. Each Local Authority shall be responsible for the enforcement of the provisions of these Regulations within their functional areas and shall take such steps as are necessary for this purpose.
Registration of producers, suppliers, authorised waste collectors and farmers
Section 32. (1) On and from the commencement date of these Regulations, each Local Authority shall cause to be established and maintained a register (hereafter in this Part referred to as ‘the register’) of producers, suppliers, authorised waste collectors, and as appropriate, farmers within its functional area,
(2) Each Local Authority shall be required to provide for the maintenance of the register, and the inspection of each premises registered therein.
S.I. No. 798/2007 — Waste Management (Packaging) Regulations 2007
These Regulations replace the previous Waste Management Regulations and are designed to promote the recovery and recycling of packaging waste. They are intended, in particular, to facilitate the achievement of the targets for the recovery of packaging waste established by Directive 94/62/EC on packaging and packaging waste as amended by European Parliament and Council Directive 2004/12/EC of 11 February 2004 so that by 31st December 2008:
(a) a minimum of 60% of packaging waste by weight is recovered; and
(b) a minimum of 55% of packaging waste by weight is recycled in total, including material specific recycling targets as follows:
(i) 60% by weight for glass, (ii) 60% by weight for paper and board, (iii) 50% by weight for metals, (iv) 22.5% by weight for plastics, and (v) 15% by weight for wood.
The Regulations impose obligations on producers who supply packaging (i.e. packaging material, packaging or packaged products) to the Irish market. A “Producer” is a business who, for the purposes of trade or otherwise in the course of business sells or otherwise supplies other persons packaging
Page 151 material, packaging or packaged goods in the course of providing a trade or service.
Major Producers are defined as “Producers” who have an annual turnover greater than €1 Million and place more than 10 tonnes of packaging onto the Irish market in a calendar year. An exemption from certain obligations is available to major producers who participate in a packaging waste recovery scheme operated by an approved body.
The Regulations provide that a producer may not supply packaging or packaged products to the Irish market unless the packaging concerned complies with specified essential requirements as to its nature and composition.
The Regulations also provide for limits on the concentration levels of certain heavy metals in packaging.
SI 798/200 Seleted Requirements for Local Authorities
Enforcement by local authorities
Section 24. Each Local Authority shall be responsible for the enforcement of these Regulations within their functional areas and shall take such steps as are necessary for this purpose.
Power of Local Authority to require submission of information
Section 25. (1) Subject to article 17 and sub-article (4), a Local Authority may, by notice in writing, require a producer to furnish within a specified period of not less than six weeks—
(a) a packaging report in respect of a specified period,
(b) such other information as may be specified in the notice regarding the use, type, quantity, origin and destination of packaging by that producer, the steps taken in order to comply with any requirement of these Regulations, and the results of those steps, or
(c) evidence of the turnover of the producer concerned.
(2) A notice under sub-article (1) may specify the manner in which any matter is to be set out or addressed in a packaging report, or the nature of the evidence to be furnished, as the case may be.
(3) A producer on whom a notice under this article has been served shall, within the period specified in the notice, comply with the terms thereof.
(4) A Local Authority may not require a producer to furnish in accordance with sub-article (1) a packaging report more frequently than once in any period of twelve months.
Page 152 (5) Producers should maintain and make available for the purposes of inspection by the Local Authority all supporting information used in the preparation of a packaging report sought under sub-article (1).
Entries in a Local Authority register
Section 26 (1) It is hereby prescribed that the register maintained by a Local Authority under section 19 of the Act shall contain entries specifying the following matters—
(a) the registration or renewal of registration of a major producer by the Local Authority in accordance with article 13 and, as appropriate, (b) the giving of a notice under article 25.
(2) Information received by a Local Authority in accordance with articles 13, 15 and 25 shall be made available at the principal office of the Local Authority concerned for inspection by any person during office hours.
Notice and information to the Agency
Section 27. A Local Authority shall furnish such information within a specified period, in such form and at such frequency as may be specified by the Agency, in relation to activities carried out in the functional area of the authority, by major producers who have registered with the authority for the purposes of complying with these Regulations.
S.I. No. 820/2007 — Waste Management (Collection Permit) Regulations 2007
These Regulations amend and replace the Waste Management (Collection Permit) Regulations 2001 and set out procedures for the making of permit applications, public consultation, consideration by local authorities of submissions in relation to permit applications, and the grant, refusal and review of collection permits by local authorities.
The Regulations now provide operators with the option of applying for a permit for specified Regions or multi Regions by means of a single application to a single nominated authority while also extending the time period for a collection permit from 2 to 5 years. The Regulations provided for conditions to be attached to collection permits specifying the requirements to be complied with in respect of the types and quantities of wastes collected and the place or places to which waste concerned may or shall be delivered for recovery or disposal.
Amendment SI:
S.I. No. 87/2008 — Waste Management (Collection Permit) (Amendment) Regulations 2008
These Regulations amend the Waste Management (Collection Permit) Regulations 2007 to correct certain typographical errors or omissions.
Page 153 SI 820/2007Selected Requirements for Local Authorities
Conditions necessary to give effect to certain provisions of Community Acts
18. A nominated authority shall attach to each waste collection permit that may be granted by it such conditions as are, in the reasonable opinion of that authority, necessary to give effect to the provisions of the Community Acts specified in the fourth schedule, insofar as such provisions are relevant to the waste collection activity concerned.
Other conditions to be attached to waste collection permits.
20. (1) The nominated authority shall attach to each waste collection permit that may be granted by it such conditions as are—
(a) in the reasonable opinion of the nominated authority, necessary to give effect to the objectives of the relevant Waste Management Plans or the National Hazardous Waste Management Plan as the case may be, and (b) stated to be necessary by a relevant Local Authority or the Agency in accordance with articles 11(4), 13 (5) or 27(1)….
….(3) The nominated authority may attach to each collection permit that may be granted by it—
(a) such reasonable conditions as are, in the opinion of that authority, necessary to ensure the proper enforcement of the permit, and (b) conditions relating to existing or proposed measures, including emergency procedures, to prevent unauthorised or unexpected emissions and to minimise the impact on the environment of any such emissions, (c) conditions to encourage the sound environmental management of waste and in particular to encourage waste prevention, reuse, recycling and recovery as set out in, but not limited to, those conditions in section 34(7) of the Act, (d) conditions requiring the making of payments by the permit holder to the authority to defray such costs as may reasonably be incurred by the authority, other than required under article 8 in accordance with the third schedule and which costs shall not exceed the actual expenditure reasonably incurred by the authority in inspecting, monitoring, auditing, enforcing or otherwise performing any functions in relation to the activity, (e) conditions requiring each vehicle to be fitted with electronic tracking technology which facilitates the surveillance operations of enforcement authorities in monitoring compliance with the waste collection permit conditions.
Entries in registers established under section 19 of the Act
Page 154 34. It is hereby prescribed that—
(1) the register established and maintained, by a nominated authority and by all other relevant local authorities in whose functional areas waste collection activities are being carried on, in accordance with section 19 of the Act shall contain entries specifying— (see subsections (a), (b) and (c) for more details)
Monitoring, Inspecting, Auditing and Enforcement
37. (1) A nominated authority, or as the case may be, a Local Authority within its own functional area, shall be responsible for the monitoring, inspection and auditing of waste collection activities and the enforcement of these regulations within their functional areas and shall take such steps as are necessary for this purpose.
(2) For the purposes of ensuring that waste collection permit holders are complying with their obligations under these regulations, a nominated authority or, as the case may be, a Local Authority within its own functional area may take all reasonable measures as are decided to be appropriate in each case, including measures prescribed under sections 14, 15, 16 and 18 of the Act.
S.I. No. 821/2007 — Waste Management (Facility Permit and Registration) Regulations 2007
These Regulations amend and replace the Waste Management (Permit) Regulations 1998 and set out procedures for the making of permit and registration applications, public consultation, consideration by local authorities of submissions in relation to permit or registration applications, and the grant, refusal and review of facility permits and registration by local authorities.
S.I. No. 86/2008 — Waste Management (Facility Permit and Registration)(Amendment) Regulations 20089
These Regulations amend the Waste Management (Facility Permit and Registration) Regulations 2007 to correct certain typographical errors and omissions.
These Regulations also replace the Third Schedule of those Regulations (specifying the classes of activity which are subject to a Waste Facility Permit application to a Local Authority or subject to Registration with a Local Authority or the Agency).
SI 821/2007 Selected Requirements for Local Authorities
Page 155 Conditions which may be attached to a waste facility permit
20. (1) A Local Authority may attach to any waste facility permit granted by the authority conditions— (see sub-sections (a) to (l))…
(2) Conditions requiring the installation of closed circuit recordings and data surveillance management systems at the facility and the maintenance of all such records for such reasonable period as may be determined by the Local Authority.
(3) Conditions requiring the Local Authority to be informed when the activity ceases at the facility.
(4) A Local Authority may attach to any waste facility permit granted by it conditions concerning the establishment and maintenance of environmental management systems which shall set out an action plan to address a 5-year period and shall be updated on an annual basis and such environmental management systems may—
(a) set out specific objectives, (b) contain measurable targets, (c) contain a requirement to comply with any written guidance issued by the Local Authority or the Agency, and (d) contain a requirement for prior agreement with the Local Authority.
Monitoring, inspection, auditing and enforcement
Section 40. (1) Local authorities or, as the case may be, the Agency, shall be responsible for—
(a) the monitoring, inspection and auditing of facilities authorised under these Regulations, and (b) the enforcement of the obligations imposed by waste facility permits and certificates of registration, including the provisions of Section 32 of the Act.
(2) Each Local Authority or, as the case may be, the Agency shall take such steps as are necessary for the purpose of checking the compliance of waste activities subject to a waste facility permit or certificate of registration in meeting —
(a) the general environmental requirements set out in article 4 of Directive 2006/12/EC, and (b) in the case of activities subject to a waste facility permit, the conditions attached to the permit, and (c) in the case of activities subject to a certificate of registration, the rules set out in the fourth schedule.
(3) Each Local Authority or, as the case may be, the Agency may develop processes, including as appropriate, audit programmes which shall be designed to verify the data provided by holders of waste facility permits and certificates of registration on waste acceptance, waste recovery and waste
Page 156 disposal. Any such audit programmes should include procedures for the assessment of annual environmental reports submitted by permit holders and registration holders and be adequate to ensure that the reported information is accurate.
(4) For the purposes of ensuring that holders of waste facility permits, certificates of registration are complying with their obligations under these Regulations, a Local Authority or, as the case may be, the Agency, or an Authorised Officer may take all reasonable measures as are decided to be appropriate in each case, including—
(a) measures prescribed under sections 14, 15, 16 and 18 of the Act, and (b) in accordance with a risk-based enforcement plan prepared on the basis of the Recommendation 2001/331/EC of the European Parliament and of the Council of 4 April 2001 providing minimum criteria for inspections in Member States and the Enforcement Handbook published by the Agency.
Entries in registers established under section 19 of the Act
41. (1) It is hereby prescribed that the register established and maintained by a Local Authority in accordance with section 19 of the Act shall contain entries specifying—
(a) in relation to each activity in respect of which a waste facility permit is granted, reviewed, revoked, transferred or surrendered, the information specified in article 10(1), (b) in relation to each activity in respect of which a certificate of registration is granted, reviewed, revoked, transferred or surrendered, the— (see additional sub-sections)
S.I. No. 113/2008 — Waste Management (Registration of Brokers and Dealers) Regulations 2008
The purpose of these Regulations is to provide for a registration system of waste brokers and dealers who arrange for the shipment of waste to and from Ireland and also the passage of waste through the State.
The regulations are necessary in order to comply with the provisions of Regulation (EC) No. 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste and Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on waste.
SI 113/2008 Selected Requirements for Local Authorities
Amendments to the Waste Management Act
Section 19.The Act shall have effect with the following specified modifications:
Page 157 (3) by the addition in section 22 of subsection 8 bis
“8 bis. There shall be included in a waste management plan sufficient information, in the form of criteria for site identification, to enable the Environmental Protection Agency (when considering an application for a waste licence) or a Local Authority (when considering an application for a waste permit), to decide whether to grant to the applicant a waste licence or a waste permit or refuse to grant to the applicant such a licence or permit, for future waste recovery or disposal facilities.”.
S.I. No. 268/2008 — Waste Management (Batteries and Accumulators) Regulations 2008
These Regulations are designed to promote the recycling of waste batteries. They will facilitate in particular the achievement of the targets for the collection, treatment, recycling and disposal of waste batteries in an environmentally sound manner established by European Parliament and Council Directive 2006/66/EC on batteries and waste batteries.
The Regulations impose obligations on persons who supply batteries to the Irish market, whether as retailers, importers or manufacturers. An exemption from these obligations is available to persons who participate in a scheme for the collection, treatment, recycling and disposal of waste batteries in an environmentally sound manner operated by an approved body
Amendment SI:
S.I. No. 556/2008 — Waste Management (Batteries and Accumulators) (Amendment) Regulations 2008
These Regulations transpose European Parliament and Council Directive 2008/103/EC of 19 November 2008 amending Directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators as regards placing batteries and accumulators on the market which amends European Parliament and Council Directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators and repealing Directive 91/157/EEC.
SI 268/2008 Requirement for Local Authorities
Enforcement
Section 40. (1) The Agency shall be responsible for the enforcement of the provisions of articles 5, 7, 9, 15, 16, 17, 18, 19, 20, 21(1)(a), 21(4), 21(5), 23, 24, 27, 28, 29, 30, 31, 32, 33(3), 34, 38, 39, 45 and 46 of these Regulations within the State and shall take such steps as are necessary for this purpose.
(2) Each Local Authority shall be responsible for the enforcement of the provisions of articles 21(1)(b), 21(2), 21(3), 21(6), 21(7), 22, 33(1), 33(2) and 42 of these Regulations within their functional areas and shall take such steps as are necessary for this purpose.
Page 158 (3) The Agency or, as appropriate, the relevant Local Authority, shall be responsible for the enforcement of the provisions of articles 25, 26, 43 and 44 of these Regulations within the State and shall take such steps as are necessary for this purpose.
(4) The Agency or a Local Authority may, for the purpose of determining compliance with these Regulations, by the service of a notice in writing on any producer or distributor, require the producer or distributor concerned to furnish in writing to the Agency or a Local Authority, as the case may be, within such period (being not less than 14 days after the date of the service of the notice) and, if appropriate, thereafter at such frequency as may be specified in the notice, such records including, but not exclusively, invoices, credit notes, dispatch or, as appropriate, delivery dockets as may be so specified.
(5) Information obtained under sub-article (4) by—
(a) a Local Authority, or any summary or compilation of, or any report based on, such information may, and shall if the Minister or the Agency so requests, be furnished to the Minister or the Agency or, as appropriate (b) the Agency, or any summary or compilation of, or any report based on, such information may, and shall if the Minister or an appropriate Local Authority so requests, be furnished to the Minister or the appropriate Local Authority, as the case may be.
Registration of Distributors
Section 42. (1) On a date not later than 1 September 2008, each Local Authority shall cause to be established and maintained a register (hereafter in this Part referred to as ‘the register’) of distributors within its functional area, who transport or, as appropriate, store waste batteries that have been accepted free of charge in accordance with the provisions of article 21.
(2) Each Local Authority shall be required to provide for the maintenance of the register, and the inspection of each premises registered therein.
(3) A distributor shall, in respect of each premises from which he or she, distributes batteries or, as appropriate, uses for the storage of batteries prior to their distribution—
(a) apply for registration, not later than 15 September 2008, or the date of commencement of business, whichever is the later, and (b) apply for renewal of such registration, not later than 31 January in each year following initial registration, subject only that a distributor or, as appropriate, a producer shall not be required to make such application within six months of initial registration to the Local Authority in the functional area in which each premises at which he or
Page 159 she stores waste batteries accepted free of charge in accordance with the provisions of article 21 of these Regulations, is situated.
S.I. No. 524/2008 — Waste Management (Certification of Historic Unlicenced Waste Disposal and Recovery Activity) Regulations 2008
These Regulations provide for the certification of historic unlicenced waste disposal sites in operation between 1977 and 1996. These Regulations apply to each closed landfill identified at which waste disposal or recovery activities were carried on without a waste licence. The regulations will provide for the registration of these facilities by the local authorities, the carrying out of a screening risk assessment of the sites and the determination of any remedial measures required (all of which will be the responsibility of the relevant Local Authority). These facilities will require a certificate of authorisation from the EPA. This certificate will determine the adequacy of the risk assessment and may specify further necessary measures to ensure the protection of the environment.
SI 524/2003 Selected Requirements for Local Authorities
Duty of a Local Authority to identify and register closed landfills
Section 5. (1) Each Local Authority shall identify by 30 June 2009 all closed landfills within its functional area and for such purposes shall have regard to the methodology set out in Appendix 1 of the Code of Practice.
(2) Each Local Authority shall have regard to the reporting requirements of Chapter 8 of the Code of Practice and maintain a register of all closed landfills identified by it pursuant to Regulation 5(1), which shall be revised and updated as necessary and at least once in each period of twelve months thereafter.
(3) The Agency shall prescribe the particulars to be entered in the register referred to in Regulation 5(2) and the form and manner in which such information shall be entered and maintained.
Duty of a Local Authority to carry out an assessment of the risk of environmental pollution
Section 6. (1) Subject to Regulation 6(2), each Local Authority shall carry out a Risk Assessment in respect of all closed landfills identified pursuant to Regulation 5(1) and for such purposes shall have regard to the Code of Practice.
(2) The Risk Assessment shall evaluate the priority to be assigned to the closed landfill site in accordance with the Risk Classification system set out in Chapter 4.3.3 of the Code of Practice.
(3) Where a closed landfill, identified by a Local Authority pursuant to Regulation 5(1), is situate on property in the ownership or control of a person
Page 160 other than the Local Authority concerned, then that authority shall request the owner or occupier of such property, as the case may be, to permit its authorised persons, officials, servants or agents, to enter onto such property for the purposes of preparing the Risk Assessment described in Regulation 6(1) or for any other purpose and any Local Authority concerned shall discharge any reasonable costs or expenses incurred by any such owner or occupier by reason of such actions as described herein.
(4) A person on whose land consent is required under Regulation 6(3) to access such land shall grant such consent in relation to the closed landfill to the Local Authority or its authorised officials, servants or agents.
(5) The Local Authority may give such directions, as it considers appropriate, to the person in Regulation 6(3), to require that person to permit the carrying out of the necessary measures pursuant to Regulation 6(3).
(6) A person commits an offence if that person fails to comply with a direction under Regulation 6(5).
Application by a Local Authority to the Agency for a certificate of authorisation
Section 7. (1) On completion of the Risk Assessment referred to in Regulation 6(1), a Local Authority shall make application to the Agency for certification of compliance with the requirements of these Regulations, which certificate shall be known as and referred to in these Regulations as a certificate of authorisation.
(2) An application under Regulation 7(1) shall be made in a format to be determined by the Agency and may require, at the discretion of the Agency, the submission of the following information or material or both— (see additional sub-sections..)
Duty of a Local Authority to comply with the terms of a certificate of authorisation
Section 8. (1) A Local Authority shall make all reasonable efforts to comply with any validated certificate of authorisation issued to it by the Agency pursuant to Regulation 7(6).
(2) Any Local Authority that contravenes Regulation 7(4) or Regulation 8(1) shall be guilty of an offence.
S.I. No. 286/2009 — Waste Management (Prohibition of Waste Disposal By Burning) Regulations 2009
The purpose of these regulations is to abolish the practice of burning of waste, by making it an offence to do so under waste legislation. An exemption under these regulations exists to allow farmers, as a last resort, to dispose of wastes generated by agricultural practices.
Page 161 Household waste cannot be disposed of by burning within the curtilage or in any other part of the dwelling or burned by use of stoves or open fires. The Regulations have been added to Local Authority enforcement priorities.
SI 286/2009 Selected Requirements for Local Authorities
Permissible disposal of waste by burning
Section 5 (1) (e) burning of waste takes place at events as may be determined locally by a Local Authority.
(2) A Local Authority may issue a notice to a person regarding steps that shall be taken regarding burning of waste and that person shall comply with the provisions of the notice.
S.I. No. 508/2009 — Waste Management (Food Waste) Regulations 2009
These Regulations are designed to promote the segregation and recovery of food waste arising in the commercial sector. They will facilitate in particular the achievement of the targets set out in Directive 99/31/EC on the landfill of waste for the diversion of biodegradable municipal waste from landfill sites to composting and to other forms of authorised treatment. They will also increase the amount of food waste that is recovered.
The Regulations impose obligations on the major sources of food waste, such as State buildings where food is prepared, restaurants and cafés, hot food outlets, canteens, hotels and larger guest houses, supermarkets and other food retailers, to segregate these materials and make them available for separate collection. Alternatively, these materials can be treated on the premises where they arise under specified conditions.
SI 508/2009 Requirements for Local Authorities
As a competent authority under the Regulations, a Local Authority, along with other competent authorities, are responsible for the supervision and enforcement of the relevant regulatory requirements within these Regulations.
Food Waste Management Plans
Section 11(5) The relevant Local Authority shall determine the adequacy, in its reasonable opinion, of a food waste management plan.
(6) In determining the adequacy of a waste management implementation report, a Local Authority shall ensure compliance with these Regulations and have regard to—5
(a) the policy objectives of the National Strategy on Biodegradable Waste 42 , and (b) the objectives and targets of the relevant waste management plan, and
Page 162 (c) the requirements of Directive 1999/31/EC 5 .
Power of a Local Authority to require submission of information
Section 12 (1) Where a producer does not produce satisfactory evidence, in the reasonable opinion of the competent authority, of appropriate management of waste in accordance with Regulation 7, a Local Authority may, subject to paragraph (8) and by notice in writing, require a producer to furnish—
(a) a food waste management implementation report in respect of a specified period, (b) such other information as may be specified in the notice regarding the use, type, quantity, origin, management arrangements and destination of food waste by that producer, the steps taken in order to comply with any requirement of these Regulations, and the results of those steps, or (c) evidence of the origin, use, type, quantities, management arrangements and destination of food waste generated by the producer concerned….
S.I. No. 566/2009 — Waste Management (Management of Waste From the Extractive Industries) Regulations 2009
These Regulations provide for measures and procedures to prevent or reduce as far as possible any adverse effects on the environment, in particular water, air, soil, fauna and flora and landscape, and any resultant risks to human health, brought about as a result of the management of waste from the extractive industries - which includes quarries and peat - and transpose Directive 2006/21/EC of the European Parliament and of the Council of 15 March 2006 on the management of waste from the extractive industries into Irish legislation.
Where an existing licence for a facility covered by these Regulations exists there is provision for avoidance of duplication by both the operators and competent authority.
SI 566/2009 Selected Requirement for Local Authorities
Major-accident prevention and information
Section 6 (3) For the purposes of the requirements under paragraph 2, each operator shall, before the start of operations, draw up a major-accident prevention policy for the management of extractive waste and put into effect a safety management system implementing it, in accordance with the elements set out in Section 1 of Schedule 1, and shall also put into effect an internal emergency plan specifying the measures to be taken on site in the event of an accident……The Local Authority shall draw up an external emergency plan specifying the measures to be taken off-site in the event of an accident. As part of the application for a licence the operator shall provide the Agency with the information necessary to enable the Local Authority to
Page 163 draw up that plan. The Agency shall as soon as possible (and no later than 3 months) after receiving the licence application notify the Local Authority that an external emergency plan is required for the applicant.
When drawing up an external emergency plan, the Local Authority should consult with the Principal Response Agencies in whose area the waste facility is located. Any external emergency plans should take account of the provisions of the Framework referred to above, and be compatible with the major emergency plans of the relevant Principal Response Agencies.
Designation of competent authority for the implementation of Directive 2006/21/EC and guidance
Section 22. (1) The Agency is the competent authority for the management of waste from extractive industries at Category A waste facilities.
(2) Save as provided for in paragraph (3) the Local Authority is the competent authority in respect of-
(a) all non-category A facilities, other than such waste facilities already licensed or licensable by the Agency, and (b) implementation of Regulation 6.
S.I. No. 32/2010 — Waste Management (Registration of Sewage Sludge Facility) Regulations 2010
These Regulations provide for the registration and regulation of sewage sludge facilities in order to meet the requirements of the Waste Framework Directive. The Regulations have implications for those involved in the collection and management of sewage sludge or septic tank waste, to register the storage facility with the Local Authority in whose area the facility is located.
Under the Regulations Local Authorities are obliged to maintain a register of sludge storage facilities, and can attach conditions of operation to any facility that it registers. Facilities already regulated under other environmental legislation such as licenced facilities under the Waste Management Acts are excluded.
SI 32/2010 Selected Requirements for Local Authorities
Register of sewage sludge facilities
Section 4. (1) The Local Authority shall enter particulars of all sewage sludge facilities registered by it pursuant to these Regulations in the register established and maintained by it pursuant to section 19 of the Act.
(2) For the purposes of Regulation 4(1), the Local Authority may prescribe the information to be entered therein, and the form and manner in which such information shall be entered and maintained, which information shall include,
Page 164 but not necessarily be limited to, the name and address of operator to whom a certificate of registration has issued.
(3) All entries and additions made by the Local Authority to the register referred to in Regulation 4(1) for the purposes of these Regulations are prescribed for the purposes of section 19 of the Act.
Determination of an application for a certificate of registration
Section 7. (1) Subject to Regulations 7(2), 7(3) and 8, the Local Authority shall issue to each applicant a certificate of registration in such form and manner and containing such information as it may prescribe which shall be valid for such period as may be specified by it but which shall not exceed five years and shall enter particulars of that sewage sludge facility in the register referred to in Regulation 4(1)
(2) The Local Authority shall not issue a certificate of registration or a renewal of registration, as the case may be, unless it is satisfied that:—
(4) The Local Authority may, if it considers it proper to do so in any particular case, regard any applicant as a fit and proper person for the purposes of these Regulations, notwithstanding that the applicant concerned is not a person to whom Regulation 7(3) applies.
Renewal of a certificate of registration
Section 9. (5) Where an operator fails to apply for renewal of registration in accordance with Regulation 9(4), the Local Authority shall remove the holder’s particulars from the register referred to in Regulation 4.
Inspections of registered sewage sludge facilities
Section 12. (1) The Local Authority shall carry out appropriate periodic inspections of registered sewage sludge facilities.
(2) The Agency shall carry out appropriate periodic inspections of Local Authority operated registered sewage sludge facilities.
S.I. No. 126/2011 — European Communities (Waste Directive) Regulations 2011
These Regulations provide for measures to protect the environment and human health by preventing or reducing the adverse impacts of the generation and management of waste and by reducing overall impacts of resource use and improving the efficiency of such use and transpose Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing certain directives, referred to in these Regulations as the waste directive.
Page 165 The vast bulk of the waste directive is already transposed by the Waste Management Act 1996 and various regulations made there under and where required the Regulations amend the 1996 Waste Management Act, provide for stand alone aspects not amenable for direct inclusion into the Act by way of specific amendments and also other consequential amendments to regulations affected by the transposition.
Amendment SI
S.I. No. 323/2011 — European Communities (Waste Directive) (No. 2) Regulations 2011
These Regulations, European Communities (Waste Directive) (No. 2), Regulations 2011, make a small number of additional amendments to the Waste Management Act 1996, omitted through typographical error, from the European Communities (Waste Directive) Regulations 2011 (S.I. 126 of 2011).
SI 126/2011 Selected Requirements for Local Authorities
Part 2 – Amendments to Act of 1996
Insertion of section 21A into Act of 1996
Regulation 7.
The Act of 1996 is amended by inserting the following section after section 21: “Waste hierarchy”.
21A.(1) The following waste hierarchy shall apply as a priority order in waste prevention and management legislation and policy:
(a) prevention; (b) preparing for re-use; (c) recycling; (d) other recovery (including energy recovery); and (e) disposal.
(2)(a) When applying the waste hierarchy referred to in subsection (1), the Minister, the Agency and the local authorities, in carrying out their respective functions under this Act, shall take measures to encourage the options that deliver the best overall environmental outcome.
(b) Such measures may require specific waste streams departing from the hierarchy where this is justified by life-cycle thinking on the overall impacts of the generation and management of such waste.
(4) In carrying out their respective functions under this Act and related waste management legislation and policy, the Minister, the Agency and the local authorities shall take into account the general environmental protection principles of precaution and sustainability, technical feasibility and economic viability, protection of resources as well as the overall environmental, human
Page 166 health, economic and social impacts, in accordance with Article 1 of the Waste Directive and section 32(1).”.
Content of Waste Management Plans
Regulation 8.
Section 22 of the Act of 1996 is amended—
(2) (a) Subject to subsection (3) and section 24, in order that plans in combination cover the entire geographical territory of the State, each Local Authority shall make a waste management plan for non-hazardous waste in relation to its functional area.
(c) The plans shall—
(i) lay down measures to protect the environment and human health by preventing or reducing the adverse impacts of the generation and management of waste and by reducing overall impacts of resource use and improving the efficiency of such use,
(ii) be in accordance with the waste hierarchy set out insection 21A,
(iii) meet the protection of human health and the environment obligations set out in section 32(1), and
(iv) meet the principles of self-sufficiency and proximity set out in section 37A.
(6) (a) A waste management plan shall—
(i) set out an analysis of the current waste management situation in the geographical entity concerned (if Regional, for example, for the Region), (ii) set out the measures to be taken to improve environmentally sound preparing for re-use, recycling, recovery and disposal of waste, and (iii) (I) set out an evaluation of how the plan will support the implementation of the objectives and provisions of the Waste Directive, (II) set out such measures or arrangements as are to betaken or entered into by the Local Authority or local authorities, with a view to securing the objectives of the plan, and (III) with regard to hazardous waste, cover the matters specified in subsection (8) in so far as they relate to its functional area.
(b) A waste management plan shall contain, as appropriate, and taking into account the geographical level and coverage of the planning area, at least the following:
(i) the type, quantity and source of waste generated within the territory, the waste likely to be shipped from or to the national territory, and an evaluation of the development of waste streams in the future; and
Page 167 (II) a requirement that, in order to fulfil this obligation, liaison shall be undertaken, as appropriate, with the Minister, the Agency, Dublin City Council and other relevant local authorities; (ii) existing waste collection schemes and major disposal and recovery installations, including any special arrangements for waste oils, hazardous waste or waste streams addressed by specific Community acts; (iii) an assessment in accordance with section 37A of the need for new collection schemes, the closure of existing waste installations, additional waste installation infrastructure and, if necessary, the investments related thereto; (iv) sufficient information on the location criteria for site identification and on the capacity of future disposal or major recovery installations, if necessary; (v) general waste management policies, including planned waste management technologies and methods, or policies for waste posing specific management problems; (vi) information as respects the integration and implementation of measures consequential on, or incidental to, the requirements of section 27A in relation to waste prevention programmes; (vii) the measures taken by the Minister to give effect to Article 22 of the Waste Directive in relation to biowaste.
(c) A waste management plan may contain, taking into account the geographical level and coverage of the planning area, the following:
(i) organisational aspects related to waste management including a description of the allocation of responsibilities between public and private actors carrying out the waste management; (ii) an evaluation of the usefulness and suitability of the use of economic and other instruments in tackling various waste problems, taking into account the need to maintain the smooth functioning of the internal market; (iii) the use of awareness campaigns and information provision directed at the general public or at a specific set of consumers.
(d) Waste management plans shall conform to the waste planning requirements laid down in Article 14 of European Parliament and Council Directive 94/62/EC of 20 December19947 on packaging and packaging waste, and the strategy for the implementation of the reduction of biodegradable waste going to landfills, referred to in Article 5 of Council Directive 1999/31/EC of 26 April 19998 on the landfill of waste as well as national legislation and policy on biodegradable waste.”,
Separate Collection of Waste and Recovery
Regulation 14.
Section 29 of the Act of 1996 is amended—
Page 168 (a) by substituting the following subsection for subsection (1):
(1) A reference in this section to the implementation and operation of a source separation programme for waste shall be construed as a reference to the taking of steps in a systematic manner for the purposes of—
(a) separating specified waste from other waste and the holding of such waste so separated prior to its collection, recovery or disposal, and
(b) giving effect to the requirements of Article 22 of the Waste Directive in relation to bio-waste.”, and
(b) by inserting the following subsections after subsection (2):
(2A)(a) It shall be the duty of waste producers and holders to ensure that waste undergoes recovery operations in accordance with sections 21A and 32(1).
(b) A person who contravenes paragraph (a) shall be guilty of an offence.
(c) The Agency and the local authorities, in carrying out their functions under this Act and related waste management legislation and policy, shall take the necessary measures to ensure that waste undergoes recovery operations in accordance with this section and sections 21A and 32(1).
(2B) Where necessary to comply with subsection (2A) and to facilitate or improve recovery, waste shall be collected separately if technically, environmentally and economically practicable and shall not be mixed with other waste or other material with different properties.”.
Principles of self-sufficiency and proximity.
Regulation 17.
The Act of 1996 is amended by inserting the following section after section 37:
Section 37A.(1)(a) In carrying out their respective functions under this Act and related waste prevention and management legislation and policy, the Minister (in cooperation with other Member States where this is necessary or advisable), the Agency, An Bord Pleanála and the local authorities shall take appropriate measures to establish an integrated and adequate network of waste disposal installations and of installations for the recovery of mixed municipal waste collected from private households, including where such collection also covers such waste from other producers, taking into account best available techniques.
Page 169 (2) The network shall be designed to enable the Community as a whole to become self-sufficient in waste disposal as well as in the recovery of waste referred to in subsection (1), and to enable the State to move towards that aim individually, taking into account geographical circumstances or the need for specialised installations for certain types of waste.
(3) The network shall enable waste to be disposed of or waste referred to in subsection (1) to be recovered in one of the nearest appropriate installations, by means of the most appropriate methods and technologies, in order to ensure a high level of protection for the environment and public health.
(4) The principles of proximity and self-sufficiency shall not mean that the State has to possess the full range of final recovery facilities within the State.”.
Part 3 Regulations to Give Effect to Waste Directive
Re-use and recycling
31. (1)(a) The Minister or any Minister of the Government concerned shall take measures, as appropriate, to promote the re-use of products and preparing for re-use activities, notably by encouraging—
(i) the establishment and support of re-use and repair networks, (ii) the use of economic instruments, procurement criteria, quantitative objectives, or (iii) other measures.
(b) The Minister or any Minister of the Government concerned, the Agency or the local authorities shall, in carrying out their respective functions under the Act of 1996, take measures to promote high quality recycling and, to this end, shall set up separate collections of waste where technically, environmentally and economically practicable and appropriate to meet the necessary quality standards for the relevant recycling sectors.
(c) Subject to section 29(2B) of the Act of 1996, by 2015 separate collection shall be set up for at least the following waste:
(i) paper;
(ii) metal;
(iii) plastic; and
(iv) glass.
(2) In order to comply with the objectives of the Waste Directive, and move towards a European recycling society with a high level of resource efficiency, and without prejudice to any other targets or obligations which may apply as a result of waste prevention and management legislation and policy, the Minister, the Agency and the local authorities shall, in carrying out their respective functions under the Act of 1996, take the necessary measures designed to achieve the following targets:
Page 170 (a) by 2020, the preparing for re-use and the recycling of waste materials such as, at least, paper, metal, plastic and glass from households and possibly from other origins as far as these waste streams are similar to waste from households, shall be increased to a minimum of overall 50% by weight;
(b) by 2020, the preparing for re-use, recycling and other material recovery, including backfilling operations using waste to substitute other materials, of non-hazardous construction and demolition waste excluding naturally occurring material defined in category 17 05 04 in the list of waste shall be increased to a minimum of 70% by weight.
Protection of human health and environment
Section 32. (1) A person holding, treating or otherwise in control of waste shall ensure that waste management is carried out without endangering human health, without harming the environment and, in particular—
(a) without risk to water, air, soil, plants or animals, (b) without causing a nuisance through noise or odours, and (c) without adversely affecting the countryside or places of special interest.
(2) A person who contravenes paragraph (1) shall be guilty of an offence.
(3) The Agency and the local authorities shall, in carrying out their respective functions under the Act of 1996, take the necessary enforcement measures to ensure that waste management is carried out in accordance with paragraph (1).
Monitoring
Section 47. (1) Each Local Authority and the Agency shall carry out, or cause to be carried out, such monitoring of the nature, extent and effects of emissions to the environment arising from the holding, recovery or disposal of waste as it considers to be necessary for the performance of its functions under this Part.
(2) Each Local Authority and the Agency shall keep and maintain or cause to be kept and maintained, such records of any monitoring carried out by it under paragraph (1) as it considers reasonable and necessary.
(3)(a) Where it appears necessary so to do for any purpose of this Part, a Local Authority or the Agency may require any person who holds or is in control of the recovery or disposal of any waste to carry out or arrange to have carried out such monitoring in relation to the activity concerned as the Local Authority or the Agency may specify and to keep and to supply to the Local Authority or the Agency such records of the said monitoring as the Local Authority or the Agency may specify.
(4) Each Local Authority and the Agency shall, if so requested by the Minister, supply to the Minister or to any person specified by the Minister, at such intervals and in such manner as the Minister may require, records of any
Page 171 monitoring carried out under this Regulation that are in its possession or control.
(5) Each Local Authority and the Agency shall carry out or take or cause to be carried out or taken such monitoring or other measures as it considers necessary to verify that any monitoring or records of such monitoring required by it under paragraph (3) to be carried out or kept are being carried out or kept.
Enforcement and penalties
50. (1) Each legal authority, the Agency or Dublin City Council, as appropriate, shall take the necessary enforcement measures to prohibit the abandonment, dumping or uncontrolled management of waste.
(2) A prosecution for a summary offence under this Part may be taken by the Local Authority..
Information
Section 49…..
(3) Information obtained under this Regulation by a Local Authority, or any summary or compilation of, or any report based on, such information may, and shall if the Minister or the Agency so requests, be furnished to the Minister or the Agency, as the case may be.
Reporting
Section 52…..
(4) Local authorities …shall provide such information to the Agency in writing, or other form of notification, including electronic means, as may be specified by the Agency for the purposes of compliance with this Regulation.
S.I. No. 355/2011 — European Communities (Waste Electrical and Electronic Equipment) Regulations 2011
These Regulations give further effect to the provisions of European Parliament and Council Directive 2002/96/EC as amended by European Parliament and Council Directive 2003/108/EC and by Article 5 of Directive 2008/112/EC of the European Parliament and of the Council.
They are designed to promote the recovery of waste electrical and electronic equipment. They will facilitate in particular the achievement of the targets for the collection, treatment, recovery and disposal of waste electrical and electronic equipment in an environmentally sound manner established by Directive 2002/96/EC on waste electrical and electronic equipment as amended by Directive 2003/108/EC.
Page 172 The Regulations impose obligations on persons who supply electrical and electronic equipment to the Irish market, whether as retailers, importers or manufacturers. An exemption from these obligations is available to persons who participate in a scheme for the collection, treatment, recovery and disposal of waste electrical and electronic equipment in an environmentally sound manner operated by an approved body established in accordance with the provisions of Part IV of these Regulations.
Amending SI
S.I. No. 397/2011 — European Communities (Waste Electrical and Electronic Equipment) (Amendment) Regulations 2011
The purpose of these Regulations is to revoke the Waste Management (Waste Electrical and Electronic Equipment Regulations) 2005 (S.I. No. 340 of 2005).
SI 335/2011 Selected Requirements for Local Authorities
Enforcement
Section 37….
(3) Each Local Authority shall be responsible for the enforcement of the provisions of articles 14(1), 14(2), 14(3), 14(4), 14(5), 14(6), 15, 17, 18(2), 30, 40 and 41 of these Regulations within their functional areas and shall take such steps as are necessary for this purpose.
(4) The Agency or, as appropriate, the relevant Local Authority, shall be responsible for the enforcement of the provisions of articles 14(8), 20, 21, 22 and 42 of these Regulations within the State and shall take such steps as are necessary for this purpose.
Registration of Distributors
Section 40. (1) Each Local Authority shall cause to be established and maintained a register (hereafter in this Part referred to as ‘the register’) of distributors within its functional area, who transport or, as appropriate, store waste electrical and electronic equipment that has been accepted in accordance with the provisions of article 14.
(2) Each Local Authority shall be required to provide for the maintenance of the register, and the inspection of each premises registered therein.
Page 173 Page 174 APPENDIX B
Page 175 Table B1 Details of NIPP outcomes 2006-Sept 2009 Action Environmental Financial Saving Organisati Result on Paper Prevention 32% reduction in paper €40,630 in UL on UL at UL & LCC consumption at University purchase of paper. of Limerick (UL) and 15% reduction in paper €10,000 in UL on waste UL consumption at Limerick management County Council (LCC). €2,578 in LCC on LCC 50 tonnes of waste purchase of paper diverted from landfill to paper recycling in UL
Roll-out of similar campaign to other local & public authorities and academic institutions within the Region
On site waste 288 tonnes of Waste cost per tonne Savoy prevention plasterboard waste was one third that of Development during segregated & recycled at other Sisk projects : Construction construction of Savoy Development undertaken in the by Sisk urban mixed use same timeframe due to development 51% of total waste quality of segregation arisings recycled from site on site. Riverpoint Increase in recycling of Apartment Toolkit to 20% in Riverpoint Complex encourage Complex Cost savings of €2,000 waste per month for waste prevention for 22% decrease in bin-lifts disposal at Riverpoint multi unit at Riverpoint complex. apartment complex
Introduction of Diversion of 15% of waste €2,970 cost savings in SkyCourt separate arisings from landfill to comparison to Shopping collection compost landfilling this waste Centre system for organic waste for food retailers Recycling rate increased €1,122 additional cost SkyCourt Improved source by 12% to 38% savings to the centre Shopping segregation of by increasing recycling Centre recyclables by 12% SkyCourt Overall waste Shopping management costs at Centre the centre decreased by €7,394 in 2008
Decoupling of Identified potential to €17,000 energy Kerry Airport energy & water reduce energy savings achievable if
Page 176 consumption consumption by 25% all measures are from growth in through low & no cost implemented. passenger measures Kerry Airport numbers €2,810 savings Water consumption achieved in one year Source reduced by 7 m³ per day. on water conservation. Kerry Airport segregation of recyclable waste 50% diversion of waste €8,165 savings on from mixed from landfill waste disposal costs waste at the between 2007 and airport 2008.
Table B2: Key Performance Indicator Details NIPP 2006-2008 Key Performance Indicator (KPI) 200 200 Organisation 6 8 Sheets of paper consumed per staff 8,15 6,96 LCC member in LCC 7 7 Average no of sheets of paper consumed 2,46 1,53 UL per 0 6 full time student in UL Cost of waste/Cost of Construction of 0.45 Sisk Building Savoy x100 Contractors Waste cost per 100 m² of construction of €80 Sisk Building Savoy 2 Contractors Development Kg’s of waste per footfall at SkyCourt 0.18 0.11 SkyCourt Shopping Centre Percentage of mixed waste presented 74 26 SkyCourt Shopping Centre Percentage of organic waste diverted to 0 15 SkyCourt Shopping compost Centre Kg’s of waste per passenger 0.27 0.15 Kerry Airport Litres of water per passenger 8.7 Kerry Airport KwH per passenger 1.39 Kerry Airport
Table B3: Fostering Sustainable Behaviour Details Locatio Work carried Out n UL Collaboration with Product Design course & Final Year student to develop a product that will promote the use of tap water by UL students. This exciting project has identified a number of options one of which will be produced and trialed on campus in 2011. Europea A comprehensive programme of activities were n Week developed & executed to promote waste prevention & for sustainable consumption. The aim was to encourage Waste participation in every day activities that can prevent Reductio waste. There were specific themes: Food Waste, n sustainable shopping, getting involved at home or work. (EWWR) The programme included: Over 80 people
Page 177 Launch of EWWR for L/C/K Region with a attended BatucaMob at the Cliffs of Moher Potential In-house events for all Local Authority staff influence for >1,000 LA staff Shopping events: Manor West Tralee, Crescent Footfall figures & Shopping Centre, Arthurs Quay Shopping Centre potential to which included the distribution of spaghetti see>12,000 measures, No Junk Mail stickers, Recipe cards to use up left-over’s, Savvy Shopping Guide 44 people in Launch of Green Town Kilmallock during EWWR, attendance 18 businesses committed to participate. Development of Green Community dimension via residential group & secondary school. Over 500 householders Hazardous Waste Prevention Initiative at Mungret given CA throughout EWWR: Leaflet & booklet information distributed to all customers. Promotion of public reuse facility at the centre.
APPENDIX C
Page 178 Table C1: Closed Landfill Draft Register Limerick/Clare/Kerry Region Tier 2/3 Tier 1 (Investigat (Investigati ion Referen EPA on Commence Year ce Reference Risk Site Name Completed) d) Closed
Limerick County Council
Morenane 22-1 S22-02456 B Landfill √ 1999
22-2 S22-02457 B Adare √ √ 1992
22-3 S22-02458 B Askeaton √ 1979
22-4 S22-02459 b Ballingarrane √ 1991
22-5 S22-02460 C Ballinvoher √ 1987
22-6 S22-02461 C Portnard √ 1978
22-9 S22-02464 C Carroward West √ 1992
Churchtown 22-10 S22-02465 A Landfill √ √ 1986
22-11 S22-02466 C Coolroe √ mid 1980's
22-12 S22-02467 C Glin Demense √ 1980
22-13 S22-02468 B Gotoon √ 1982
22-15 S22-02470 B Kilmacat √ 1980
22-17 S22-02471 C Knocknacarriga √ 1988
22-18 S22-02472 B Lacknagoneeny √ 1982
22-19 S22-02473 B Knockbrack √ 1996
22-21 S22-02475 B Newpark House √ 1984
Newtown 22-22 SS22-02476 C Landfill √ 1974 - 1982
22-23 S22-024577 C Tankardstown √ 1981
22-24 S22-0245578 B Toreen √ 1984
22-49 S22-0245579 A Southill √ 1987
Limerick City Council
22-25 HigA Ballynanty √ 1998
√ 22-53 St Mary’s Park √ (Completed)
Kerry County Council
22-27 B √ Ardfert 1980 22-28 A √ √ Rockfield 1988
Page 179 Tier 2/3 Tier 1 (Investigat (Investigati ion Referen EPA on Commence Year ce Reference Risk Site Name Completed) d) Closed
Kerry County Council (ctd..)
22-29 B √ Listowel 1989 22-30 B √ Sneem 1990 22-31 A √ √ Tralee 1994 22-32 A √ Dingle 1996 22-33 B √ Leanmore 1996 22-34 A √ Ahascra 1997 Capped in accordance with EPA 22-35 √ Licence Coolcaslagh 1999 Capped in accordance with EPA 22-36 √ Licence Milltowm 1999 Capped in accordance with EPA 22-37 √ Licence Kenmare 1999 Capped in accordance with EPA 22-38 √ Licence Caherciveen 1999 22-51 B √ 1980’s Castleisland Clare County Council
C Lisdoonvarna √ 1980 22-39 Milltown C Malbay √ 1980 22-40 C Kilmihil √ 1980s 22-41 C Corofin √ 1980s 22-42 B Kilrush √ 1992 22-43 Ennistymon B Landfill √ 1997 22-44 A Whitegate √ 1998 22-45 C Kilkee landfill √ 1979 22-52
Page 180 Prepared by Philippa King & Carol Sweetnam
Limerick/Clare/Kerry Regional Waste Management Office
Lissanalta House,
Dooradoyle Road,
County Limerick.
Tel 061 496596
Fax: 061 583955
Email [email protected]
Website: www.managewaste.ie
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