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

This will not, however, give any certainty regarding the meeting of Landfill Directive
targets. If a treatment for residual waste has the same cost as landfill, inclusive of
levies, then the chances are that the treatment facility will not be built for the simple
reason that the landfill option still exists, and the landfill operator might be better
placed to drop prices in the short terms than the treatment facility. Additional
certainty is required, and this ought to be achieved under the EPA’s proposed pretreatment
approach.
We have proposed that the levy is announced and increased over a period of three
years. We would suggest that to give certainty to the meeting of Landfill Directive
targets, a ban on the landfilling of waste which does not meet the 10 mg O2/g d.m.
stability criterion is implemented in 2013. We also suggest that some thought is given
to the potential need for exemptions from the restriction in situations where, come
2013, insufficient treatment capacity is available (locally). The lesson of the Dutch
experience, however, is that if exemptions are available, some may seek to avail
themselves of them indefinitely. Consequently, if a waste holder has no option other
than to landfill residual waste, such an exemption could be granted, but at a cost to
the holder of the waste. This ‘exemption levy’ should maintain the stimulus to build
alternative treatments to landfill.
56.3 ‘Government Policy’ and the Waste Framework Directive
It should be noted that non-incineration technologies for dealing with residual waste
are unlikely to be developed as long as the perceived view is that ‘government policy
is that residual waste should be incinerated’.
It is widely held that Government policy is to favour thermal treatment over other
forms of residual waste treatment. There is, it would appear, no clear and
unequivocal reason to support thermal treatment over other forms of residual waste
treatment, and in any case, to the extent that the levy proposed above simply seeks
to internalise externalities, the levy itself effectively removes the rationale for any
such explicit discrimination – the aim of the levy is to allow the market to determine
which facility is most appropriate.
In European law, the revised Waste Framework Directive proposes that incinerators
which exceed a specific threshold of efficiency in energy generation should be defined
as ‘recovery’. The conditions are as follows:
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This includes incineration facilities dedicated to the processing of municipal
solid waste only where their energy efficiency is equal to or above:
— 0,60 for installations in operation and permitted in accordance with
applicable Community legislation before 1 January 2009,
— 0,65 for installations permitted after 31 December 2008,
using the following formula:
Energy efficiency = (Ep - (Ef + Ei))/(0,97 × (Ew + Ef))
In which:
Ep means annual energy produced as heat or electricity. It is calculated with
energy in the form of electricity being multiplied by 2,6 and heat produced for
commercial use multiplied by 1,1 (GJ/year)
Ef means annual energy input to the system from fuels contributing to the
production of steam (GJ/year)