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

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It acknowledges the role <strong>of</strong> a number <strong>of</strong> potential supplementary measures in<br />

reducing the level <strong>of</strong> BMW sent to landfill and accelerating progress toward the BMW<br />

diversion targets, including:<br />

715<br />

accelerated planning for MBT facilities, minimum standards for MBT waste,<br />

support <strong>of</strong> composting initiatives, the role <strong>of</strong> incineration and increased<br />

coverage <strong>of</strong> pay by unit and ‘three-bin’ systems nationally.<br />

51.5.2 MSW - Pre-treatment and Residuals <strong>Management</strong><br />

In the Autumn <strong>of</strong> 2008, the EPA consulted upon a Technical Guidance Document<br />

entitled Municipal Solid <strong>Waste</strong> - Pre-treatment and Residuals <strong>Management</strong>. 877 This<br />

was subsequently finalised and issued in June 2009. 878 The document suggests that<br />

the initiatives set out in the Guidance were intended to assist delivery <strong>of</strong> Ireland’s<br />

obligations under the EU <strong>Waste</strong> Framework Directive (2006/12/EC), the EU Landfill<br />

Directive (1999/31/EC), and the EU IPPC Directive (96/61/EC).<br />

Article 6 <strong>of</strong> the Landfill Directive requires, inter alia, that: 879<br />

Member States shall take measures in order that:<br />

(a) only waste that has been subject to treatment is landfilled. This<br />

provision may not apply to inert waste for which treatment is not<br />

technically feasible, nor to any other waste for which such treatment<br />

does not contribute to the objectives <strong>of</strong> this Directive, as set out in<br />

Article 1, by reducing the quantity <strong>of</strong> the waste or the hazards to<br />

human health or the environment;<br />

For existing landfills, this was to take effect ten years after the publication date in the<br />

Official Journal, and for new landfills, the requirement took effect two years after its<br />

publication (i.e. on the date <strong>of</strong> transposition).<br />

Ireland’s approach to implementing this particular aspect <strong>of</strong> the Directive appears to<br />

have been somewhat delayed, particularly with regard to new landfills (for which the<br />

requirement to ensure that all waste landfilled has been pre-treated has been in<br />

place, formally, for eight years).<br />

The general thrust <strong>of</strong> the Pre-treatment Guidelines is positive. The Guidelines have<br />

ambitious objectives, effectively seeking to simultaneously:<br />

1. Comply with Article 6 <strong>of</strong> the Landfill Directive;<br />

2. Define BAT (though the term is not always applied in the conventional context);<br />

3. Deliver on Landfill Directive targets; and<br />

877 EPA (2008) Municipal Solid <strong>Waste</strong> - Pre-treatment and Residuals <strong>Management</strong>: An EPA Technical<br />

Guidance Document, Consultation Draft, Johnstown Castle Estate: EPA.<br />

878 EPA (2009) Municipal Solid <strong>Waste</strong> - Pre-treatment and Residuals <strong>Management</strong>: An EPA Technical<br />

Guidance Document, Johnstown Castle Estate: EPA.<br />

879 Council Directive 1999/31/EC <strong>of</strong> 26 April 1999 on the landfill <strong>of</strong> waste Official Journal L 182 ,<br />

16/07/1999 pp. 1 – 19.<br />

<strong>International</strong> <strong>Review</strong> <strong>of</strong> <strong>Waste</strong> <strong>Policy</strong>: Annexes

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