Submission on the draft Eastern and Midland Region Waste Management Plan, Ireland, 30-Jan-15

ZERO WASTE ALLIANCE IRELAND
Towards Sustainable Resource Management
__________________________________________________________
Túr na Gaoithe
Philipstown HBX
Castleblaney Road
Dundalk
County Louth
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Eastern - Midlands Draft Regional
Waste Management Plan 2015 - 2021
Public Consultation
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Submission to the Eastern &
Midlands Regional Waste
Coordinator
30 January 2014

of 2
__________________________________________________________
Túr na Gaoithe
Philipstown HBX
Castleblaney Road
Dundalk
County Louth
30 January 2015
Regional Waste Coordinator,
Eastern & Midlands Region Waste Management Office,
Block 1, Floor 6,
Civic Offices, BY EMAIL TO:
Dublin 8. emwr@dublincity.ie
Dear Sir,
Eastern - Midlands Draft Regional Waste Management Plan 2015 - 2021
Public Consultation
Submission to the Eastern & Midlands Regional Waste Coordinator
On behalf of Zero Waste Alliance Ireland (ZWAI), I am attaching an electronic copy
of our observations on the draft Eastern & Midlands Regional Waste Management
Plan 2015 – 2021.
The submission provides a brief overview of our policy and objectives on waste,
supporting the well-established strategy and policy of aiming for “Zero Waste”, and
supporting repairing, preparation for re-use, reusing and recycling materials and
objects, in accordance with the revised European Waste Hierarchy and the
“Circular Economy”.
Our observations express concern that the Eastern & Midlands Regional Waste
Management Plan as drafted gives too much power to Dublin City Council and the
other local authorities of the Greater Dublin Area, and that the midland counties will
have very little or no influence in waste-related planning matters, policies or
objectives which might be more appropriate at county or local level.
We are also concerned that much too high a proportion of re-usable and recyclable
discarded materials is sent overseas for processing, adding the environmental cost
of transportation, fuel use and emissions from vessels transporting these materials.
We propose that, to reduce or eliminate this dependency, Ireland should follow the

Observations by Zero Waste Alliance Ireland on the draft Eastern & Midlands region WMP
Page 2 of 2
example of other countries and that appropriate financial and other supports should
be provided in the Waste Management Plan for the establishment of small, locally
based repairing, preparation for re-use and recycling workshops, of the type we
have seen in the Province of Flanders, Belgium. Similar initiatives are being
undertaken in Ireland, but they are facing a barrier of negligible financial support by
local authorities.
One of our basic principles in ZWAI is that discarded materials should be
segregated at source (before they become “waste”), and that these materials
(together with recyclable wastes) should be used for the benefit of the communities
which have produced them, and that waste collection and utilisation facilities
should be community owned and controlled (but allowing for the possibility that
private companies may carry out some of this activity as a service under contract
and under careful regulation and control). We would therefore wish to see this type
of approach included in the Waste Management Plan, together with a firm
statement that the handling of our discarded materials must not be left to “market
forces”, for the purpose of private gain and profit.
In general, it is our observation that the draft Waste Management Plan contains
some very appropriate and welcome policies and objectives, but these are not
clearly stated, and the language used is, in many places, weak and ambiguous.
We hope that the above observations, together with those in the attached
submission, will help to influence the Plan towards a more ecological approach to
waste management – in which human societies behave more like natural systems
which produce nothing which cannot be fed back into the Earth’s transformational
and long term sustainable processes.
Yours sincerely,
Ollan Herr Jack O’Sullivan
On behalf of Zero Waste Alliance Ireland.
ZWAI-E&MRWMP-001 Covering letter to Waste Plan Co-ordinator, 30-Jan-15.doc

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__________________________________________________________
Eastern - Midlands Draft Regional Waste Management Plan 2015 - 2021
Public Consultation
CONTENTS
Page
1. Introduction and preliminary comments .. .. .. .. 1
2. Excessive Size of the Waste Management Region Covered by the
Eastern - Midlands Draft Regional Waste Management Plan 2015 –
2021 .. .. .. .. .. .. .. .. .. 3
3. Zero Waste Alliance Ireland (ZWAI) policy on waste and the
management of waste .. .. .. .. .. .. 5
4. Implementing the circular economy .. .. .. .. 7
5. Charging by weight for waste, an improved system of waste
disposal levies, and better financial support for re-use, repair and
recycling .. .. .. .. .. .. .. .. 11
Proposed virgin material tax .. .. .. .. .. .. 13
Plastic type labeling tax .. .. .. .. .. .. 14
Financial support for recycling .. .. .. .. .. 14
6. Separation at source – integrating household waste segregation
with the Building Regulations .. .. .. .. .. 14
Existing resource conservation and recovery in Irish Building Regulations 15
Part N – Waste resource separation and segregation in the home .. 15
Health protection .. .. .. .. .. .. 15
Formal early planning for resource separation in the kitchen 15
Storage size .. .. .. .. .. .. .. 16
For longer storage periods .. .. .. .. .. 16
Saving on the pay-by-weight charges by composting .. 17
Domestic rotating drum composters .. .. .. .. 18
Domestic vermicomposting .. .. .. .. .. 19
7. Public Consultation .. .. .. .. .. .. .. 20
Figure 1: The “Linear Economy” and the “Circular Economy” 8
Appendix I Notice on the website of the Department of the Environment, Community
and Local Government inviting Comments on the draft Regional Waste
Management Plans
Appendix II" Acknowledgment received from Dublin City Council on 05 February 2015
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ZWAI-E&MRWMP-011 Contents Pages of Submission on draft EastMidRegWasteManPlan, 30-Jan-15.doc

1
__________________________________________________________
Túr na Gaoithe
Philipstown HBX
Castleblaney Road
Dundalk
County Louth
!
Eastern - Midlands Draft Regional
Waste Management Plan 2015 - 2021
Public Consultation
!
Submission to the Eastern & Midlands Regional Waste
Coordinator
30 January 2014
!
!
1. INTRODUCTION AND PRELIMINARY COMMENTS
!
One of the key issues addressed in the Government's waste management
policy document, “A Resource Opportunity – Waste Management Policy in
Ireland” (July 2012), is regional waste management planning; and the policy
reminds us that waste management planning has been a statutory function of
local authorities since 1996. Under Section 22 of the Waste Management Act,
1996, local authorities were given the discretion to come together to discharge
their waste management planning functions in groups, as a result of which 10
regional waste management plans were drawn up and implemented.
!
This regional approach appears to have worked reasonably well, in that the
number of landfills declined significantly, and a more strategic approach was
taken by the groups of local authorities.
On the other hand, the waste management plans failed to bring about any
significant elimination of waste, to radically reduce the quantities of waste
generated, or to encourage repair, re-use and re-cycling. The result of nearly
20 years of waste management has led to a situation where almost all of
Ireland’s recyclable materials are exported, with very little re-processing or
recycling carried out in the country.

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

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2. EXCESSIVE SIZE OF THE WASTE MANAGEMENT
REGION COVERED BY THE EASTERN - MIDLANDS
DRAFT REGIONAL WASTE MANAGEMENT PLAN
2015 – 2021
!
Our first observation is that the creation of such an extremely large waste
management area would copper-fasten the practice of transporting Dublin’s
waste as far as possible from the city. While acknowledging that it is very
difficult for a city to deal with its own wastes within its own boundaries, it is our
view that imposing Dublin’s waste on rural communities is not the most
appropriate solution. In the absence of adequate policies to implement
extended producer responsibility, to adequately encourage waste reduction,
resource recovery, repair, re-use and recycling or composting of organic
materials, landfilling still remains one of the options taken by the waste industry
in Ireland.
It is therefore our submission that this new and expanded waste management
region, which would come under the control of Dublin City Council, would result
in that Local Authority having far too much power in comparison with all of the
other Local Authorities within the same region. Not only is Dublin City Council
extremely powerful by reason of its economic strength, but to add further to its
power would shift the balance even more in its favour.
The Regional Waste Management Plan as drafted further copper-fastens this
imbalance of power because of the over-riding importance given to the policies
and objectives of the Plan. In relation to the current planning framework, the
draft Regional Waste Management Plan states that:1
“The waste plan is a statutory planning document setting out
policies for the development of waste treatment infrastructure and
sits on the same planning tier as the city and county development
plans.
These local planning frameworks are deemed (under law) to
contain the objectives of the relevant waste management plan in
force for that particular area.
In the event of a conflict arising between an objective in the waste
plan and that of a city or county development plan, the waste plan
objective takes precedence and permission may be granted”.
1
Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021; section 2.2
(Planning Framework), page 8. Eastern‐Midlands Region Waste Management Office, Dublin
8.

4
The quotation above makes it quite clear that policies and objectives on waste
management, drawn up by the Dublin local authorities, would over-ride any
local policies or objectives in the County Development Plans of any of the other
counties in the Waste Management Region. For example, a decision by Laois
County Council or Longford County Council to develop a strong policy of waste
elimination, with clear objectives and ambitious targets for repair, re-use and
recycling, could be over-ruled on the basis that any such objectives were not
consistent with those in the Eastern and Midland Regional Waste Management
Plan. To consider another example – if Westmeath or Longford County Council
were to refuse planning permission for a hazardous waste processing facility on
the grounds that it would not be compatible with the County Development Plan
for the relevant county, could Dublin City or County Council make a successful
appeal to An Bord Pleanála on the grounds that the provision this facility was
part of the Regional Waste Management Plan ?
We have seen how Dublin City Council has been prepared to use its muscle in
order to abstract water from the River Shannon instead of focusing its efforts on
leakage control, demand management and other water saving measures.
Giving Dublin City Council and the other local authorities in the Greater Dublin
Area power to set waste policy in an area encompassing some twelve counties
is, in our view, an inappropriate and retrograde step.
!
Dublin’s track record in the past regarding the promotion of incineration rather
than zero waste, is a cause of worry to those communities outside of Dublin
who have landfills and incineration already imposed on them. Furthermore, the
way in which Dublin City Council has promoted incineration, and has entered
into a widely criticized contract with an incinerator operator which will result in
an extremely heavy cost burden to Dublin’s citizens into the future, increases
our reason for concern. As the members of the City Council are only too well
aware, the size of the proposed incinerator, the cost of the project to date, and
the terms of the contract have been the subject of justified criticism by a very
significant number of environmental organisations and residents of Dublin, and
by the European Commission.
It may also be appropriate to refer to the judgement of the High Court in the
case taken by Panda Waste and others against Dublin City Council in 2009,
when Mr Justice Liam McKechnie found that Dublin City Council abused its
dominant position in the capital's waste market, and he ruled that the local
authority's decision to change the capital's waste collection system is invalid.
The Court also concluded that an earlier review of the city’s waste, undertaken
by the Council, was prejudged and the outcome predestined.
The above events do not inspire confidence in Dublin City Council’s ability to
take on the role of Regional Waste Co-ordinator, and to manage waste and

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control waste collection and disposal of the wide area of 12 counties proposed
in the new waste management regional policy.
Our further concern is that the expansion of Dublin’s waste management policy
into Leinster will not be about creating a greater market for creating jobs in
waste resource management, repair, reprocessing or recycling - we fear that it
will primarily provide a justification for the extension of landfill facilities and the
expansion of the capacity of the incinerator operated by Indaver at Carranstown
near Duleek.
Our final concern is that these large “waste management regions” may be a
stepping stone towards the installation of large-scale incineration facilities in all
three regions. While we have no direct evidence for this, we can find very little
other justification for the establishment of such areas. On the other hand, it is
clear that giving Dublin City Council control over potentially much larger sources
of waste would strengthen the Council’s intention to pursue incineration as the
primary method for dealing with waste.
!
3. ZWAI POLICY ON WASTE AND THE MANAGEMENT
OF WASTE
!
As a background to addressing in detail the Eastern & Midlands Draft Regional
Waste Management Plan 2015 – 2021, we wish to describe our policy on waste
generation and elimination, and on re-use, repair, recycling and disposal.
Our belief and approach is that waste management must not rely on landfills,
incineration, so-called “waste-to-energy” solutions, or any other “end-of-pipe”
approaches. Future waste management must recognise that:
! While land filling may have to remain an acceptable means of dealing in
the short term with locally generated residual quantities of non-recyclable
and non-compostable municipal solid wastes, the only long-term
sustainable solution is to completely eliminate the production and sale of
materials in the economy which cannot be re-used, recycled or naturally
biodegraded;
! Instead of organising systems that efficiently dispose of or recycle our
wastes, we can and must learn from nature to design systems of
production and consumption that have little or no waste to begin with --
this will result not only in a saving of scarce resources, but will re-adjust
our relationship to the earth’s material assets from a linear to a cyclical
one, enhancing our ability to live comfortably while reducing
environmental damage;

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! The only long-term sustainable solution to municipal, industrial and
agricultural waste management is to eliminate the production of materials
which are toxic and which cannot be naturally biodegraded, re-used,
recycled or re-processed as secondary raw materials for other productive
industrial or commercial uses;
! “Zero Waste” is an integrated realistic whole-system approach to
addressing the problem of society’s unsustainable resource flows – it
includes waste elimination at source through product design and
producer responsibility, together with waste reduction strategies further
down the supply chain such as cleaner production, product dismantling,
recycling, re-use and composting; and,
! The implementation of “extended producer responsibility” on all section
of Irish Industry is a key requirement for the achievement of Zero Waste.
Practical steps towards achieving the goal of Zero Waste should focus on
solutions that are being put into practice in many countries, including examples
of clean industrial production, waste elimination, successful recycling and “zero
waste” practices worldwide. Achieving this goal does not require complex or
advanced technology solutions, only the realisation and full understanding that:
" Waste is made by mixing a variety of discarded materials; therefore
segregation at source is an essential pre-requisite to sustainable waste
management;
" It is essential that waste is considered as a community resource, and not
as a bulk commodity to be removed by disposal to landfill or by
incineration;
" Communities should be encouraged to handle their discarded materials
responsibly;
" Communities cannot resolve the waste problem alone and should not be
forced to clean up after irresponsible industries;
" Countries and communities faced with discarded materials and objects
they cannot reuse, recycle or compost have to demand that industry
stops producing them; total recycling is not approachable without
industry's willing cooperation;
" Sustainable waste management or “Zero Waste” combines community
practices such as reuse, repair, recycling, toxic removal and composting,
with industrial practices such as eliminating toxics and re-designing
packaging and products for the environmental and ecological demands
of the 21st century;
" Sustainable waste management brings together the need to develop
sustainable communities and sustainable industry and business; and,

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

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transformed into products which eventually end up as waste (see figure 1
below).
This policy is also consistent with the Government's current waste management
policy – “A Resource Opportunity” – which aims to maximise the resources that
can be recovered from waste, using the most appropriate technologies. “A
Resource Opportunity” does not explicitly mention the circular economy, but it is
based on the EU waste hierarchy and encompasses a range of measures
across all 5 tiers in the hierarchy; namely, prevention and minimisation, reuse,
recycling and recovery of energy.2
Figure 1: The “Linear Economy” and the “Circular Economy”
The policy also states that reuse and preparation for reuse will be encouraged
and promoted through the renewed national waste prevention programme, so
as to facilitate the reuse of unwanted goods between businesses and between
members of the public.3
The Eastern and Midlands Draft Regional Waste Management Plan 2015 –
2021 also shows a significant and very welcome change in policy direction
towards the concept of the circular economy, and the Plan refers to “A
Resource Opportunity” as “the Government’s blueprint for a circular waste
economy”. Apart from the fact that the expression “circular waste economy” is a
contradiction in terms, the plans include targets which, if they are achieved, will
2
"A Resource Opportunity - Waste Management Policy in Ireland". Published by the
Department of the Environment, Community and Local Government, July 2012; Foreword,
page 3.
3
"A Resource Opportunity - Waste Management Policy in Ireland". Published by the
Department of the Environment, Community and Local Government, July 2012; page 10.

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underpin “the transition towards a circular economy and will be a stepping stone
for further progress”.4
These targets take their lead from the European Commission’s proposals which
emphasise the circular economy as a means of pushing the boundaries of
recycling in all Member States. As proposed by the EU, and taken up as a
strategic approach and vision for regional waste management in Ireland, the
circular economy model fundamentally considers waste as a valuable resource
to be recirculated into systems of near-continuously maintaining, repairing,
reusing, refurbishing and recycling materials and products.
The existing make-take-dispose linear models where products having reached
their end of life are discarded as waste are no longer viable. For the current
linear approach to continue and thrive it assumes resources are plentiful and
will constantly be available at low cost prices to meet demand. The economic
reality is very different.5
On 02 July 2014, the European Commission adopted the Communication
“Towards a Circular Economy: A Zero Waste Programme for Europe”, the
purpose of which is to establish a common and coherent EU framework to
promote the circular economy.6
A very similar policy had earlier been advocated by the European Commission
under the title of “Industrial Symbiosis”, whereby different participants derive
mutual benefit from sharing utilities and waste materials, with the aim of turning
waste from one industry into useful feedstock for another one. Secure access
to resources has become an increasingly strategic economic issue, while
possible negative social and environmental impacts on third countries constitute
an additional concern. Improving the re-use of raw materials through greater
'industrial symbiosis' (where the waste of some firms is used as a resource for
others) across the EU could save €1.4bn a year and generate €1.6bn in sales.7
The European Commission has also pointed out that management of secondary
raw material flows requires reliable and harmonised data for the estimation of
4
Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021; section 5.4.2
(Performance Targets), page 45. Eastern‐Midlands Region Waste Management Office,
Dublin 8.
5
Eastern - Midlands Draft Regional Waste Management Plan 2015 – 2021; section 5.2 (Our
Vision), pages 36-37. Eastern‐Midlands Region Waste Management Office, Dublin 8.
6
Towards a circular economy: A zero waste programme for Europe, 2014. Communication
from the Commission to the European Parliament, the Council, the European Economic and
Social Committee and the Committee of the Regions; Brussels, 2.7.2014 COM(2014) 398
final.
7
Roadmap to a Resource Efficient Europe; Communication from the Commission to the
European Parliament, the Council, the European Economic and Social Committee and the
Committee of the Regions, 2011. Section 3.1.2 (Boosting efficient production), page 6.
Brussels, 20.9.2011 COM (2011) 571 final.

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composition, patterns of supply and quantity of wastes generated over the
year(s), in order to achieve reliable and predictable feed-stocks of secondary
raw materials for industrial plants. Industrial symbiosis needs coordination
between a variety of stakeholders, including industry, research institutions, civil
society organisations, public authorities and policy makers, together with an
increased awareness of producer responsibility for waste avoidance.8
The above topic was one of the principal research priorities identified in the EU
Seventh Framework Research and Innovation Programme, 2007 – 2013, in the
thematic areas of 'model business and consumer behaviour', 'product
production design', and 'policy', which included sustainable lifestyles and
consumption behaviour, sharing utilities and waste materials, producer
responsibility for waste production, increased product life-spans, enabling
material reuse, recycling, recovery, industrial symbiosis leading to closed-loop
processes, and consumption behaviour and lifestyle change. It is now a major
part of the Horizon 2020 work programme – the largest EU Research and
Innovation programme ever with nearly €80 billion of funding available over 7
years (2014 to 2020) – in addition to the private investment which this EU
funding will attract.
It is therefore clear that the operational concepts of the “circular economy” and
“industrial symbiosis” will replace the older and now outmoded linear model in
which products are discarded as waste at the end of their life. When we classify
discarded products and materials as waste, we almost automatically consider
how they should be disposed of, an activity which always incurs a cost, even if
the material or product may be recycled or some of its embodied energy
recovered.
ZWAI therefore fully supports the vision for a Circular Economy described
briefly in the Eastern - Midlands Draft Regional Waste Management Plan 2015
– 2021, and would urge implementation of the following objectives:
!
8
Horizon 2020 Work Programme 2014 – 2015; adopted on 10 December 2013. European
Commission Decision C (2014)4995 of 22 July 2014; Part 12. Climate action, environment,
resource efficiency and raw materials -- Waste-1-2014: Moving towards a circular economy
through industrial symbiosis; Page 8 of 88.

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

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

13
To summarise, it is our observation and recommendation that higher levies on
incineration and landfilling should be used to encourage the development of re-
use industries. In addition to the pay-by-weight scheme as proposed, ZWAI
supports other revenue-neutral taxes for similar environmental protection
reasons to achieve additional environmental and employment goals.
Proposed Virgin Material Tax
We suggest that a new tax needs to be put on virgin raw materials. Ours is
probably going to be the last generation that continues to be so thoughtless and
indifferent to the imminent final exhaustion of our finite resources. These are
the materials that will be reaching their world resource limits over the coming
years or decades; which will not be available to future generations and are not
replaceable. An effective economic advantage should be given to any of the re
usable or recycled form of this material in order to encourage the circular
economy that Europe wants us to adopt. Oil is the obvious big example of a
strategically important resource that will shortly no longer keep up with world
demand. The problem with the present tax on petroleum is that so little of this
money is being strategically spent to reduce our dependency on this finite
resource. Phosphorous is another example. World phosphorous rock
resources are projected to become expensive as the resource starts to run out
over the coming 2 or 3 decades. We need to impose a tax now to invest in the
infrastructure to recycle phosphorous

14
Plastic Type Labeling Tax
A problem exists where the type of plastic in a container is so often not clearly
marked or easily identified. At one public amenity centre in County Louth there
is a skip for PE milk bottles, a second for PET lemonade bottles and a 3rd skip
for a wide variety of mixed plastic containers. Ideally instead we should be
facilitated to separate much more of the mixed plastic waste so that the over
whelming portion of plastic containers are separated into their own plastic type.
It takes too much time at present to make a close enough inspection of the
plastic container to see if it is PE, PET, PS or PP. Taxes should be levied on all
plastic containers that do not have a clear indication of the type of plastic so it
can be more easily recycled.
Financial Support for Recycling
The finance section of the Executive Summary for the Eastern and Midland
Region shows the funding requirements under the new plan, and it is clear that
lowest amount of financial support is for recycling.
It is our observation that it is neither credible nor honest of the State to be
claiming to be supporting a circular economy while spending only €8 million for
recycling out of a total spend in the waste sector of €118 million. The table of
Infrastructure Element Costs provides the shocking disclosure that €260 million
is projected to be spent by the private sector on thermal treatment of waste; but
for reuse, reprocessing and pretreatment the estimated cost is not quantified.
We ask why not? Is there not a need to spend as much or even more to
develop the circular economy?
6. SEPARATION AT SOURCE – INTEGRATING
HOUSEHOLD WASTE SEGREGATION WITH THE
BUILDING REGULATIONS
We have pointed out in section 3 above that ZWAI consider that “waste” is
produced when a variety of discarded materials are mixed; and that therefore
segregation at source is an essential pre-requisite to sustainable waste
management.
If the goal is to maximize segregation, we need to create a positive culture of
resource separation at the earliest stage in the cycle; in the home. In Ireland,
when designing new houses and apartments, almost no thought was put into
planning for the management and separation of kitchen waste. With the current

15
pressure from Europe to move to a circular economy we believe that Irish house
design must facilitate this new culture and new thinking. We propose that the
Technical Guidance Documents in the Irish Building Regulations would have a
new section that encourages and facilitates home owners in this regard. While
this is not strictly part of the draft Eastern and Midlands Regional Waste
Management Plan, we believe that such a move could be given support by
including it as an objective.
Existing Resource Conservation and Recovery in Irish Building
Regulations
It’s worth noticing that we already have regard to the concept of resource
conservation and recovery within the Irish Building Regulations. We have in
Part L guidance for heat insulation which will help to conserve our oil imports.
In Part H we have likewise been progressive, we now encourage rainwater
harvesting as well as grey water segregation for treatment and recycling.
We suggest that we should also positively facilitate solid waste recycling within
the Building Regulations. The thrust of the wording for a new section in the
Technical Guidance Documents would be as follows.
Part N – Waste Resource Separation and Segregation In the
Home
Health protection
The separation of kitchen and general household waste should be carried out in
a manner that avoids human health hazards, prevents the attraction of rats or
mice and minimises or avoids noxious odours.
Formal early planning for resource separation in the kitchen
When planning for a zero waste home, the planning for waste separation and
storage at planning application stage should be undertaken. Facilities for the
temporarily storage of kitchen waste should be provided for in all new kitchen
designs in the same way as happens for cookers, fridges, dish washers etc.
Architectural drawings in planning applications should show the location of the
waste separation & storage cupboard within or directly adjacent to the kitchen.
House plans from the architect should clearly show where in the kitchen the
resource separation space is to be located. The resource storage facilities
need to be carefully considered so that it is close enough to be practical for the
person who is un-wrapping food and cooking the meal.

16
Storage size
Depending on family size a storage space volume of between 0.25 and 0.4 m^3
should be properly provided for integration inside kitchen islands, cupboards or
purpose made presses. Where a number of deep drawers are being
considered they must be of easily washable material such as polyethylene or
polypropylene. No toxic plastic materials are to be recommended in contrast to
other materials that are themselves not recyclable. PVC for example or other
plastic materials comprised of chlorine or bromine should be avoided as they
produce dioxins when burned or incinerated.
This self standing set of stacked plastic drawers in the photo is an example of a
system that meets the requirements above. The drawers sit snugly in the frame
so that mice cannot enter. The food waste bins on top have snap shutting
plastic handles on the lids to keep in the smell of the waste food. The
translucent drawers and the frame are of polypropylene plastic. The owner is
able to wash the plastic surface every so often.
Ideally however these drawers would be hidden from view behind the door of a
press or cupboard. Most families nowadays prefer that cupboard shelves with
cups and plates are hidden.
For Longer Storage Periods
The photo below shows how this particular family are able to visit the Public
Amenity Centre less often.

17
The self standing drawers are taken from the kitchen and each drawer is
emptied into one of 6 small blue wheelie bins. They also have smaller plastic
containers for batteries, bulbs, aluminium, CD’s etc. When full the six bins are
taken in an open topped trailer to the Public Amenity Centre in Dundalk on
about 7 occasions in the year. The cost is €2 for each visit so their overall
annual cost is €14 / annum
The Guidance Document should assist the family and the architect to plan for a
3 wheelie bin system or a larger system with more bins and better segregation
as shown above. So often modern compact houses are built by developers to
use the smallest footprint with no thoughtful planning for segregated solid waste
management.
Saving on the Pay by Weight charges by Composting
Our proposal for a new Part N of the Building regulations should also offer
guidance and minimal standards for home composting of organic kitchen waste.
When composting the primary health protection goals are to avoid vermin and
odours.

18
Domestic Rotating Drum Composters
Rotating drum composters like that shown in the photograph below are 900 mm
long and 700 mm diameter, with 8 sides and 2 inches of insulation. It has two
internal compartments. One is for filling and the other for composting. The
outside body is of aluminium. It rotates on a horizontal shaft. The owner has it
located near to the back door under a rain shelter to keep it dry. The Guidance
Document would require the planned location of this composter
The householder merely adds a few handfuls of wood pellets anytime she/he is
filling with food waste. This type of composter usually becomes very warm and
may steam with the heat that is generated inside it. The owner claims that with
this rotating drum being up off the ground that she/he has never had any
problem with rats. This is in contrast to a previous composter that sat on the
ground and attracted rats.
Since food waste is relatively heavy, we believe that more people will begin to
home compost to save on the pay by weight charges. The Guidance Document
should advise people on the obvious pitfalls and the measures needed to avoid
vermin and odour nuisances. It should advise on the space requirements and
the protection that is needed from wet weather. The owner also advised that it
should be higher off the ground so that a wheel barrow can be positioned
underneath to collect and take away the finished compost.

19
This is a now a mature technology. We recommend this is one type of
composter that should be described in the Technical Document. We believe that
people should have access to advice on this subject in the Building Regulations
as a way to reduce the weight of their bins being collected.
Domestic Vermicomposting
Vermicompost is the product or process of composting using particular species
of worms.
This self standing drum system has three removable trays for the food waste
and worms. It measures 470 mm diameter and the body is 430 mm tall. It
stands on 5 plastic legs. Earth worms consume waste food that is not acid such
as orange skins and onions. Relative the rotating composter it is therefore
slightly more restricted with the waste food that it will accept, but for small
families its compact size has some advantages.

20
7. PUBLIC CONSULTATION
!
!
It is our submission that the consultation process is inadequate and does not
conform to the most basic principles of the Aarhus Convention, for the following
reasons:
• It is unclear whether the Department of Environment, Community and
Local Government or Dublin City Council are driving this draft Regional
Waste Management Plan and other regional waste management plans,
together with the changes in the areas and numbers of waste
management regions;
• There had been no real public consultation about the policy change
which could directly affect many people whose waste is collected by
private companies operating in any or all of the counties listed in the
notice;
• There appears to be no opportunity for any participation in the decision-
making process, in further contravention of the principles laid down in the
Aarhus Convention.
• No information is given of the various separated resources being
collected at Public Amenity Centres. We don’t know the final destination
of the materials being collected. We don’t have any analysis of the Irish
jobs being supported in the handling, transport, reprocessing, or re-
manufacure.
!
!
!
!
Ollan Herr Jack O’Sullivan
On behalf of Zero Waste Alliance Ireland.
!
!
30!January!2015!
!
!
!
!
!
!
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!
!
ZWAI Submission on draft EastMidRegWasteManPlan, draft 3, 30-Jan-15.doc

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

RE: Observations by Zero Waste Alliance Ireland on the draft Regional
Waste Management Plan for the Eastern & Midlands Region.
EMWR <emwr@dublincity.ie> 5 February 2015 at 14:56
To: Jack O'Sullivan <jackosullivan2006@gmail.com>
Cc: Hugh Coughlan <hugh.coughlan@dublincity.ie>
Dear%Mr.%O'Sullivan,
Please%note%your%submission%was%received%on%the%30th%Jan%2015;%and%whilst%your%
submission%will%be%read%there%is%no%statutory%obligation%to%consider%the%content%
when%plan%amendments%are%being%considered.
Regards,
Emma Cassin
|Project Co-ordinator| Eastern & Midlands Regional Waste Management Plan |
|Dublin City Council | Eblana House | Marrowbone Lane, Dublin 8, Ireland |
T +353 1 222 4312| F +353 1 411 3440 | emma.cassin@dublincity.ie | www.emwr.ie
Smaoinigh ar an timpeallacht sula ndéanann tú an ríomhphost seo a phriontáil. Please
consider the Environment before printing this mail.!
From: Jack O'Sullivan [jackosullivan2006@gmail.com]
Sent: 30 January 2015 15:05
To: EMWR
Subject: Observations by Zero Waste Alliance Ireland on the draft Regional Waste
Management Plan for the Eastern & Midlands Region.
Regional Waste Coordinator,
Eastern & Midlands Region Waste Management Office,
Block 1, Floor 6,
Civic Offices,
Dublin 8.
Dear Sir,
Eastern - Midlands Draft Regional Waste Management Plan 2015 –
2021
On behalf of Zero Waste Alliance Ireland (ZWAI), I am attaching an electronic
copy of our observations on the draft Eastern & Midlands Regional Waste
Management Plan 2015 – 2021, together with our covering letter to you.
Yours sincerely,
Jack O'Sullivan
Zero Waste Alliance Ireland
Appendix(II Acknowledgment(received(from(Dublin(
((((((((((((((((((((((((((((((((((City(Council(on(05(February(2015

************************************
Environmental Management Services
Aplinkos Apsaugos Konsultacijos
Comhairleoirí Comhshaoil
Environmental and Planning Consultants
Outer Courtyard,
Tullynally,
Castlepollard,
County Westmeath,
Ireland.
Loc8 Code: MJM-20-W96
Telephone +353 44 966 2222
Fax +353 44 966 2223
E-mail jackosullivan2006@gmail.com
*************************************
ZWAI-E&MRWMP-005 Email acknowledgement from Dublin City Council, 05-Feb-15.doc

Submission on the draft Eastern and Midland Region Waste Management Plan, Ireland, 30-Jan-15

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