International Review of Waste Management Policy - Department of ...

through the input of data from Repak and from national data complied by the EPA,
and that the performance indicators to be used would be:
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� The increase in levels of recovery/recycling;
� The increase in the numbers in the compliance scheme or as Self Compliers;
and
� Increases in the roll out of required recycling infrastructure including bring
banks etc.
It is worthy of note that the requirements, upon producers, under Article 5 of the
Regulations, to separate packaging relates to the sorting of material for ‘recovery’.
This reflected the definition in the 2006 version of the Waste Framework Directive of
‘recovery’. So as to avoid the possibility that separately collected fractions of
packaging waste, that were intended to be recycled were subsequently sent for
recovery at incineration plants, it would seem sensible to re-word this in the existing
Regulations.
12.8 Implementation Costs
12.8.1 Implementation Costs of Packaging Recycling Policy
The implementation costs for setting up and operating the administrative measures
primarily revolve around providing staff and training resources. The staffing resource
is spread across all those organisations described in Section 12.4 of these Annexes.
The staff required range across the regulatory and guidance authorities and
organisations, from policy and guidance staff in DoEHLG and the EPA, to enforcement
officers in the enforcement network of the EPA & Local Authorities, to technical and
guidance staff in the EPA/Repak, to the project staff at the compliance scheme
Repak, to external consultant auditors of the compliance scheme, to staff in
stakeholder groups like the Irish Waste Management Association and IBEC.
Local Authorities indicated during the 2006 consultation that there is an existing
burden on their staffing levels with the current requirements of the regulations. 237
They flagged that the reduction in the de minimis threshold would increase the
number of companies in the ‘Major Producer’ category and which would place a
resource burden on Local Authorities in meeting administration and enforcement
requirements with the same number of staff.
The EEA report notes:
29/09/09
“No specific estimates of the public authorities' administrative costs (general
administration, monitoring of packaging and packaging waste, etc.) or the
costs of the self-complying companies are available.”
Repak administers the monthly data processing and auditing of subsidy claims by
Repak authorised service providers (Private and Public waste management collectors
237 DoEHLG (2006) ‘Statement on Regulatory Impacts’, Responses from 2006 Consultation