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

33.8 Implementation Costs
The costs of implementing this Circular and its requirements are not known. Scope
clearly exists in the Irish context, however, for net costs of service provision to be
lower as a consequence of this measure than in a counterfactual system where
biodegradable waste is landfilled. This is for the simple reason that landfill gate fees
are very high, and biowaste treatment costs are likely to be lower. This suggests the
potential for the measure to be of an ‘invest to save’ nature, especially if the levy
proposed for residual waste in the Main Report is adopted. The issue of collection
costs is examined further in Annex 64.0.
The reality will depend on the details of implementation. A critical issue will be how
the development of infrastructure can be made such that capacity grows in line with
expected quantities of waste captured for treatment. Furthermore, the lack of any
clear link between collectors and their method, and the treatment of the waste,
suggests there may be some difficulties whereby treatment systems which are
developed are not ideally suited to the materials being collected.
33.9 Response from Public and Industry
We are not aware of any document which highlights the response from public and
industry. Anecdotally, it is known that some private sector operators are not well
disposed to the prospect of being required to roll-out ‘brown bins’. It is interesting to
note, in this respect, that whilst such operators might perceive this as an unnecessary
infringement from the Irish Government, Ireland may yet have its hand forced anyway
through measures highlighted in the Waste Framework Directive. In this context, the
reluctance of operators becomes less straightforward to understand.
There appears to be some misunderstanding regarding the role of MBT and what it
might be capable of achieving. MBT is a pre-treatment for residual waste. It is
intended to complement, not replace, separate collection of biowaste. The outputs
from MBT processes are unlikely to be of equivalent quality to those derived from
source separation, and the associated benefits are likely to be considerably reduced.
33.10 Effects on Technical Change / Innovation
The expected changes are as highlighted in the document itself, though as also
hinted above, the detailed outcomes depend upon approaches to collection of waste,
and choices of treatment technology. Currently, the most likely approach to collection
and treatment is likely to be co-collection of food and garden waste with the material
being composted. This might not deliver the best outcome for society.
33.11 Social and Distributional Consequences
These are unclear as yet and will depend upon the detailed manner of
implementation. In principle, given Ireland’s relatively high landfill gate fees, if
collection systems are designed efficiently, householders might pay less owing to the
high avoided cost of disposal. However, much depends upon charges levied at
biowaste facilities, and on the behaviour of households (and how this is incentivised).
This question is intimately bound up with the design of the collection system, and the
background costs of residual waste treatment / disposal.
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