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

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4. Effectively push for source separation of dry recyclables and biodegradable
wastes.
Particularly in respect of the last of these four points, it is not clear that the approach
is the best mechanism. However, a reader of the document could be forgiven for
thinking that the Guidance is effectively seeking to become ‘the measure’ by which
Ireland meets its Landfill Directive targets in a fairly encompassing approach.
In general, the Guidance is well intended. However, some issues remain outstanding
on a reading of the document, including:
� It lacks a detailed description of exactly what is expected to happen when the
Guidance enters into force (as, in principle, it already has done). The date
appears to have been set more with regard to the date set for complying with
Article 6;
� It stipulates some requirements which may deliver rather marginal benefit
whilst imposing significant costs. Notable in this regard is the shift from a
stability standard of 10 mg O2/g d.m. down to 7 mg O2/g d.m. The rationale
given is that the approach is in line with continuous improvement outlined
under BAT, but this does open up a range of questions regarding, for example,
whether benefits are commensurate with costs, and how the same approach
is translated to other facilities to which the requirement to demonstrate BAT
also applies; 880
� The targets for operators are set in terms of the proportion of BMW in MSW
accepted at landfills, which might be an awkward way to specify the means to
meet Landfill Directive targets unless the management of Irish waste in future
follows the exact path which seems to have been modelled for it; and
� It would seem to be incredibly difficult (perhaps impossible) to enforce the
targets in a meaningful way, especially in the short term, and it is notable that
no discussion on the issue of regulation and enforcement is to be found within
the document.
Notwithstanding the above comments, the EPA remains confident in its approach,
and that the outcome will be satisfactory, but it is clear that the approach is very
much in the development phase.
880 In communications, the EPA expresses the view that this delivers additional reductions in
biodegradability, which is no doubt true. The problem is that in order to meet the revised target, in
principle, no change in ‘technique’ is necessarily required. Rather, the change is likely to lead to a
considerable increase in the cost of achieving the standard through increasing the necessary retention
time (although, no doubt, additional re-jigging of the facility could be made to achieve the higher
standard, but mid-operation, this would be expensive). The extent to which this benefit could be said to
be worth the additional cost of meeting the amended standard is not clear, but our own research
suggests that the opposite is likely to be the case, possibly with a substantial cost for minimal benefit
(see, for example, Eunomia (2008) ‘Biostabilisation’ of wastes: making the Case for a Differential Rate
of Landfill Tax,
http://www.eunomia.co.uk/shopimages/Eunomia%20Landfill%20Tax%20Paper%20Final.pdf )
29/09/09