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

Note 2: For the first two biodegradable waste diversion obligations (2010 & 2013), a
national 3 bin system (including for catering/ commercial sources of
biowastes) will likely ensure, on its own, that the EU Landfill Directive
diversion/treatment obligations are met through diversion from landfill of the
biodegradable dry recyclables and the organics.
Note 3: This will translate (approximately) to the tonnage of BMW accepted at
landfills in 2010 being less than 25% of the tonnage MSW generated
nationally; falling to < 15% in 2013, and < 9% in 2016.
Note 4: SRF – Solid Recovered Fuel of defined specification for use as a fuel in coincineration
plants, or other energy uses as may be approved, where
available.
Source: EPA (2009) Municipal Solid Waste - Pre-treatment and Residuals
Management: An EPA Technical Guidance Document, Johnstown Castle Estate: EPA.
In the medium- term, the establishment of a stability threshold is to be welcome.
However, the Guidance document does not spell out unequivocally that the meeting
of the stability criterion is intended to imply that the waste will be treated as ‘no
longer biodegradable’ for the purposes of the Landfill Directive. Indeed, if such a
measure had been considered earlier, this would have been the only measure
required to implement the Landfill Directive, though other instruments would have
been necessary to ensure that environmental benefits were realised through the
approach. 881 In practice, it might be preferable for the Guidance to:
718
� Establish a pre-treatment requirement independently of the meeting of Landfill
Directive targets, this being specified to allow the requirements to be easily
met. 882 There does not, after all, appear to be any underpinning rationale for
suggesting that what constitutes pre-treatment one day is not pre-treatment
on another, but the Guidance appears to change the requirement for ‘pretreatment’
in line with what is required to deliver Landfill Directive targets. This
would allow the Government to discharge its obligations under Article 6 of the
Landfill Directive; and
� Establish a stability threshold for landfilling of all municipal waste, this
requirement to be met not by 2016, but by 2013. Where, in a given region, the
necessary infrastructure is absent, exemptions would be granted, but only
where applied for in advance, and at additional cost to the holder of the waste.
881 This measure alone would not necessarily have delivered the most desirable outcome. It might,
however, have delivered on the Directive targets since it would have implied that no biodegradable
municipal waste could be landfilled.
882 The UK provides one example of a country which has defined pre-treatment very loosely. Pretreatment
includes most activities which alter the nature of the waste, including sorting of a material
from the waste stream. There are definitely drawbacks in such an approach, but the urgency of
meeting the Article 6 targets might suggest a similarly simple approach. In Scotland, the regulator
effectively assumes that the pre-treatment requirements are met so that the measure implies very little
for waste producers (though some collectors have used the requirements to encourage some
customers to sort materials where they had not been doing so previously).
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