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

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56.2 Proposed Policies to Deal with Residual <strong>Waste</strong> in the<br />

Context <strong>of</strong> the Landfill Directive<br />

In principle, three options appear to be available regarding the Landfill Directive:<br />

1) Re-couch the national targets as regional, or local authority ones, and implement<br />

a mechanism to ensure these are met. This might lead Ireland to a situation akin<br />

to the UK’s landfill allowances schemes, where <strong>Waste</strong> Disposal Authorities are<br />

effectively allocated quotas <strong>of</strong> allowances limiting the quantity <strong>of</strong> biodegradable<br />

municipal waste they could landfill. One major difference between the UK and<br />

Ireland, however, is that local authorities have control over what happens with the<br />

totality <strong>of</strong> what is defined as municipal waste in the UK. The same is not true for<br />

Ireland, and nor would it be true if Irish local authorities were made directly<br />

responsible for the collection and management <strong>of</strong> household waste, as proposed<br />

in Section 3.6. The large (and, hitherto, rapidly growing) quantity <strong>of</strong> commercial<br />

waste would still be open to the marketplace to determine the management <strong>of</strong>.<br />

Hence, this mechanism does not seem to recommend itself, at least not for ‘all<br />

municipal waste’, since no addressee is appropriate for the target being proposed;<br />

2) A second option would be to choose an addressee for Landfill Directive targets<br />

that does have control over how waste is managed. By the time waste arrives at<br />

landfill, decisions have already been made, so this could not be the landfill<br />

operator itself, unless the main implementing mechanism was a requirement to<br />

pre-treat (see below). The only real alternative appears to be the collectors.<br />

Collectors could, in principle, be given landfill allowances relating to the proportion<br />

<strong>of</strong> (biodegradable) municipal waste they handle (another option would be to<br />

auction the allowances), this proportion declining each year. They would be<br />

allowed to trade these with other collectors so that those who had surplus<br />

allowances (who had recycled more, or ensured more waste was treated) could<br />

sell to those who were in deficit. One issue with this is that rather like the regions<br />

/ local authorities in Ireland, collectors are not always in a position to influence<br />

investments in treatment. The level <strong>of</strong> vertical integration across collection and<br />

treatment / disposal varies across collection companies. The mechanism might<br />

also compromise any efforts to develop indigenous infrastructure, with exports a<br />

likely means used to meet targets (rather more so than already happens). Finally,<br />

the required accounting mechanism would be difficult to design and implement in<br />

a fair manner, and there would be significant issues <strong>of</strong> moral hazard to be<br />

overcome; and<br />

3) A third option is to re-cast policy such that, whatever other instruments are in<br />

place, the market is incentivised and regulated to deliver on the targets. Here, a<br />

wide range <strong>of</strong> options are available, and they could, in principle, be considered.<br />

However, as highlighted above, there are some key policies already in<br />

development regarding residual waste and the Landfill Directive. In essence, we<br />

believe that with some adaptation, these will take Ireland a long way to meeting<br />

its Landfill Directive targets in 2013. The 2010 issues are clearly more pressing,<br />

as discussed above.<br />

833<br />

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

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