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

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29/09/09
There will be a certain amount of biodegradable municipal waste for which it
is not feasible to achieve a sufficient level of segregated collection to satisfy
the required landfill diversion targets. Accordingly, there will also be a need to
collect this material as residual BMW and to provide treatment – either
thermally or through some form of stabilisation – to reduce the biological
activity to imperceptible levels and thereby ensure achievement of the
mandatory diversion targets.
Regions / counties must decide how their Waste Management Plans can
address these requirements.
Finally, it states:
Each Waste Management Plan should meet the targets of this Strategy,
identifying the combination of collections and treatment types that suit local
conditions and objectives. Each Plan should be reviewed on that basis.
Each Annual Implementation Report to be prepared by local authorities on the
implementation of the Waste Management Plan, as required under Key Point
13 of Waste Management: Taking Stock and Moving Forward, should record
progress made in relation to the National Strategy on Biodegradable Waste
over the previous year. The format to be followed in the Annual
Implementation Report will be specified in a Circular letter issued to all local
authorities by the DoEHLG.
What might not be clear to any of the planning regions is which targets really apply to
them, and how should they implement the requirements to deliver the NBS? Do they
all know, for example, how much BMW they should consider they were landfilling in
1995? What is their ‘quota’ of the national allowance? If this is not known, how could
the relevant calculations be performed? 874 Do the BMW projections imply ‘targets’?
Who do any of the targets actually fall upon? If some local authorities do not collect
any waste, is it reasonable to assume that they will take up the challenge of such
targets seriously? Would it be appropriate to apply sanctions to them if they don’t,
and if sanctions are not to be applied, how realistic is it to expect targets to be met?
In short, whilst the document seeks to chart a way forward for Ireland to meet Landfill
Directive targets, and whilst it contains some interesting targets in terms of home
composting and source separation, the manner in which these should cascade down
(to the regional level) is not always clear. The presumption appears to have been that
the regions will implement these, even though the regions simply do not have the
competence to deliver – in and of themselves – the outcomes.
Interestingly, most of the Annual Implementation Reports for the Regional Waste
Management Plans make little or no reference to targets that the NBS suggests they
should be implementing. Since there are very few Annual Implementation Reports
which have been produced by the Regions, and since the NBS was completed only
after most of the Regional Waste Management Plans were updated, then it would
874 The Draft NBS did actually apportion the national allowance to the regional level, which would have
been a starting point for implementation at the regional level.