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60.0 Grant Funding 60.1 Introduction The public sector is the main source of the grant funding, offering financial assistance to organisations across the public and private sectors. The public sector sources the funds both from general taxation, and from specific ring-fenced pots of money, derived from particular taxes associated with potential environmentally detrimental activities, e.g. landfilling. The funds are then used to finance projects which offset these detrimental activities, or support environmental policy goals. The OECD suggests: 902 29/09/09 ‘The golden rule of public funding suggests that governments should support only those investments that are economically efficient but not financially viable’. 1111 By following the OECD’s advice, grants should fund projects which can prove that their reliance upon the funding is not long-term, and that they have the capacity to function sustainably, i.e. without the grant support, in the future. This generally makes it important to ensure that the applications for funding demonstrate an ability to stand on their own feet once grant support falls away. In some cases, revenues may be used to support specific activities on an ongoing basis, but in these cases, it is not clear what purpose the ear-marking purpose serves. If there are areas of activity which require ongoing support, presumably in the public sector, then it becomes unclear why the activity should not be supported through general taxation rather than ear-marking per se, though clearly, it can be argued that the two are equivalent. Having looked at the Irish case (Section 60.2), this report seeks to identify current international examples of grant funding (Section 60.4 to Section 60.12). Following this, the Irish case will be examined and recommendations will be made. 60.2 Grant Funding in Ireland 60.2.1 National Development Plan In Ireland the co-ordinating structure for the planning of government over a programme period is the National Development Plan (NDP). Historically, over past programme periods for the NDP, a significant feature of the NDP was the co-funding of some programmes and measures with income from the Irish exchequer along with EU funding. This has significantly reduced in the latest NDP period (2007-2013), in which an expected €3 billion from the EU Structural Funds was planned for within the €184 million expenditure planned for priority investment in the period. 1111 OECD (2007) Handbook for Appraisal of Environmental Projects Financed from Public Funds, report to OECD by the Task Force for the Implementation of the Environmental Action Programme, Available: http://www.oecd.org/dataoecd/10/63/38786197.pdf
NDP 2000-2006 Waste management & waste infrastructure development planning have been included within the NDP in regional programmes in the past, to facilitate funding of waste management activities at regional & local levels. The National Development Plan website outlines the mechanism through which the allocation of funds was administered, in particular where receipt of funding is negotiated and agreed with the EU; 1112 903 “To draw down E.U. Structural Funds, each Member State has to draw up and submit a plan setting out its investment priorities for the funding period….in Ireland’s case, the National Development Plan (NDP)…. (the subsequent) … agreement resulted in a Community Support Framework (CSF.)…” The NDP and the CSF form the basis of the implementation of the agreement for EU funding. Within the previous NDP (2000-2006), there were two regional assemblies which were the administrative bodies within which funding was administered through regional programmes; the Border, Midland & Western (BMW) assembly and the Southern & Eastern (S & E) assembly. The regionalisation arrangements negotiated by Ireland in the context of the Agenda 2000 Agreement resulted in the designation of two regions in Ireland for Structural Funds Purposes: � The Southern and Eastern Region (S&E Region) which will qualify for a six year phasing out regime for Objective 1 Structural Funds up to the end of 2005, and � The Border, Midland and Western Region (BMW Region) which has retained Objective 1 status for Structural Funds for the full period to 2006. Following this designation, two new Regional Assemblies where established and came into effect on the 21st July 1999 under the Local Government Act, 1991 (Regional Authorities) (Establishment) Order, 1999. The Assemblies are comprised of nominated elected representatives of the regional authorities within their Region. The principal functions of the Regional Assemblies are: � To promote the co-ordination of public services in the Southern and Eastern Region � To manage the Southern and Eastern Regional Operational Programme under the National Development Plan (2000-2006) � Monitor and make proposals in relation to the general impact of their regions of all E.U. Programmes of assistance under the Community Support Framework 1112 National Development Plan (2009) National Development Plan Website, Available: http://www.ndp.ie/viewdoc.asp?fn=/documents/eu_structural_funds/overview/structural_funds.htm &mn=euso&nID=3 International Review of Waste Policy: Annexes
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International Review of Waste Manag
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29/09/09
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ii 32.0 Levy on Waste Paints - Inte
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Glossary of Acronyms iv 29/09/09 AB
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vi 29/09/09 MSW Municipal solid was
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WASTE POLICIES - EXISTING FRAMEWORK
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3 departing from the hierarchy wher
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7. The inclusion of measures to pre
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7 Reuse; Reuse; Reuse; for example
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ut both grow. “Absolute decouplin
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1.4 Waste Recycling and Composting
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13 waste from these sources. Member
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Management (Food Waste) Regulations
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17 Such measures may include an acc
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19 � endeavour to reduce the use
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21 the European Union. Apart from l
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23 1. Member States shall set up a
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1.6 The Incineration Directive The
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1.7 The UNECE / Stockholm Conventio
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29 � Lindane to Annex A; � Pent
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2.0 Policy Instruments for Waste Ma
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33 agencies), and occasionally unde
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Mechanisms which operate through th
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identical, but in practice they hav
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39 that firms may still need to be
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41 � Recycling investment tax cre
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43 � Lack of communication betwee
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3.2 Issues with Current Situation I
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47 Greenstar claims that when the l
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3.3 Market Failure Currently in Ire
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51 franchise agreements reduce the
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as set out by the EU is limited in
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The beneficial network effects, or
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3.6 Recommendations What is often d
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59 which was designed to reflect a
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61 1. Whether the private sector ha
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4.0 The Role of Local Authorities 4
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that there have been no significant
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Local authorities have no obvious m
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introduced (and under which, they w
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71 International Review of Waste Po
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statutory waste management plans. I
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Each region has devised, and period
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uneconomic infrastructure and regio
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79 programme of measures to achieve
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Waste referred to in paragraph 1 is
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It is suggested that the regions sh
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6.0 Review of Irish Policy on Preve
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2. High quality data relating to wa
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company linked to the municipality
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infrastructure with a high emphasis
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93 and liaise with local authoritie
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To date the Market Development Grou
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Table 6-1: Generation of Municipal
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No adjustment was made to the proje
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whilst initiatives for unsolicited
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7.0 Pay-By-Use - Ireland 7.1 Outlin
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One of the waste management commitm
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eporting in the Annual National Was
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109 � In the absence of a kerbsid
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in case study areas, and an increas
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shifts/by separate staff, which in
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not reflected in reduced costs to c
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extent to which this compromises an
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and residual waste fee not so great
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121 � Choosing collection schemes
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8.3 Key Organisations Involved in I
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of material generated as waste (sin
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Figure 8-2: Balance of Costs and Be
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counterfactual. This type of approa
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131 � Bin-volume based (i.e. wher
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133 � Sack-based schemes with cha
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Table 8-4: Costs under Flat Rate Fe
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to this type of abuse given a) its
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the effect of certain variables on
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effects are not always verifiable i
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A French study (results shown in Fi
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Therefore, it would seem reasonable
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In many jurisdictions, where the pr
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149 “M&S [Marks & Spencer] sell t
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cost of residual waste treatment is
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eduction in waste quantities. The m
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A useful report on illegal dumping,
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Generally, the view which prevails
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9.0 Pay-by-use - Germany 9.1 Outlin
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Table 9-2: Charges for Residual Was
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163 Environmental Advisors (Sachver
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Figure 9-2: Quantities of Residual
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The bulky waste collections, Figure
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The net effect of these changes for
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the market such as waste sluices (e
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Prior to the system’s introductio
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The case of Schweinfurt is truly ou
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10.1.2 Approaches to Selective Coll
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10.4 Key Organisations Involved in
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FOST-Plus reports the following col
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to recover costs in such a way that
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11.0 Landfill Levy - Ireland 11.1 O
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187 � Landfill operators. Local A
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Table 11-2: Trends in Household Was
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191 • The effects of the Repak Pa
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positive. In 2007, of the €32,398
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11.8 Response from Public and Indus
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When the landfill levy was first in
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12.0 Producer Responsibility, Packa
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Although the European legislation d
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Table 12-1: Distribution of Respons
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205 (v) 15% by weight for wood, sup
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207 Companies that supply packaging
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Data from both Repak and self-compl
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Table 12-3: Average Compound Rate o
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The EEA report identifies the role
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The same study went on to highlight
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217 materials at source, effectivel
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and processors). In terms of the re
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Repak members, and non-major produc
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In their submission of information
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225 a. Direct costs of compliance (
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As noted above, there are differenc
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Directive. The current Regulations
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each year by an Industrial Structur
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generally cheaper to collect as it
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Netherlands Netherlands Netherlands
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Figure 13-1: Packaging Recycling an
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Country Country 241 % % of of colle
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It can be seen that against this me
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Figure 13-4: German License Fees Pa
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This is likely to have been depende
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Table 13-9: Financing Sources for R
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iv) Operational Operational Operati
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Table 14-2: Operators of Dual Syste
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provided by the DSD. Through the DS
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Following a poll in 2004, it became
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packaging has to be licensed by the
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15.0 Producer Responsibility - Flan
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265 � The industrial federations
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used to reimburse (inter)municipali
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Consumers can bring old and expired
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15.3.7 Waste Tyres The implementati
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273 � which treatment facilities
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VALORFRIT reimburses the municipali
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Figure 15-3: Belgian Packaging Wast
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279 � Widespread use of PBU; �
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Figure 15-4: Collection for Recycli
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283 � by January 2015, reuse and
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RECUPEL has continually sampled 5 %
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is currently being performed to ide
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Table 15-7 Green Dot Fees for Packa
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Moreover, the provisions of BEBAT n
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293 • All other types of oil gene
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procedure. It would be considerably
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16.0 Deposit Refund Systems - Inter
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same order as the cost savings from
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Country Country System System Year
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NT$13.01 per kg (US$0.39 at January
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collectors. These super-collectors
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A study in 2002 reviewed the outcom
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315 The existing studies show that
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Figure 16-2: Performance of US Stat
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Figure 16-5: Return Percentages of
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This is not to deny the possibility
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323 in in in packaging, packaging,
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harm caused by plastics in the mari
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327 Deposit containers would be tra
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have to be compared with the costs
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Of particular interest are some of
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Figure 16-7: Economic Cost per Tonn
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One of the concerns within Europe h
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(e.g. brought from Germany) so that
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Another pre-requisite, partly becau
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341 International Review of Waste P
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343 � Council of Environmental Ad
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step towards turning people away fr
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The sectors that profited from the
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349 � Willingness of the industry
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Green-Schools is run by An Taisce f
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18.3 When was the Policy Introduced
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355 � Green Homes: The Green Home
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Figure 18-1: Green Homes Research -
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composter. There are similar saving
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information on the various themes i
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Producers must register with the na
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365 • 2008: The Waste Management
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367 • Approved producer complianc
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the generation of electrical and el
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80% of WEEE primary processing take
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outed to charities and schools to d
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since June 2006 to guide and co-ord
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377 � Category 10 - Automatic dis
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table are the ‘2008 Review of Dir
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National National Register Register
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383 � The financial structures as
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purchased), though some offer it vo
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In order to facilitate their financ
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that product, the risk that the mat
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particular streams of WEEE. For exa
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Table 20-2 gives the amount of each
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demand that the receiving facilitie
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Table 20-3: Range of Total Costs fo
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kg), and a TV (15 kg), finding the
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20.10 Lessons Learned Administrativ
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Historical and ‘orphan’ waste,
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in 2012. Hence, the revision may im
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equipment. Furthermore producers do
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409 � 31 st December 2005: Almost
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411 � Regarding “new” WEEE (e
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ate of WEEE collected after the int
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A serious problem is the illegal ex
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22.0 Producer Responsibility, ELVs
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practice previously resulted in the
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421 of that producer's brand or for
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Ireland would be able to meet the r
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22.6.2 Environmental Benefits Assoc
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According to this paper: 427 � Th
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oth pieces of legislation is to res
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23.0 Producer Responsibility, ELVs
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driven the reclamation industry to
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23.2.7 Country-specific Characteris
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In addition to the benefits associa
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key reports highlight the importanc
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Government in the form of additiona
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affected. In any event, the effect
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447 happen and because a reasonable
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24.2 Policy Context and Reason for
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time of writing, though it is under
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24.7 Environmental Benefits The Bat
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24.11 Social and Distributional Con
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25.0 Producer Responsibility, Batte
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459 � The competent authorities s
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1995. 537 This proliferation is pri
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463 � Countries where separate co
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This has been possible under a broa
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specific battery types, they might
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For automotive and industrial batte
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25.6.1.2 Retailer Take-back Schemes
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Table 25-5: Average Cost per Kilogr
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effectively be financed at a cost o
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Collection methods in Europe have p
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26.2 Reasons for the Policy Accordi
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Figure 26-2: German Battery Composi
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26.11 Evasion and Enforcement The c
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27.0 Plastic Bag Levy - Ireland 27.
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27.5.1 Evaluation Studies Available
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491 � Retailers find the effects
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ags in 2003, compared with 36% in 1
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27.10 Social and Distributional Con
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27.14 Lessons Learned 27.14.1 Gener
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499 � Higher rates of recycling;
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Table 28-2: The Organisation of the
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same period of 9.8%. 600 The Danish
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that only 8,000-10,000 businesses w
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28.12 Lessons Learned The Danish sc
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a government body, the revenue is
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511 � Lubricating oil; � Antifr
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Considering the impact on the consu
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30.0 Product Taxes - Belgium 30.1 O
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and the Minister of Economic Affair
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Figure 30-1: Market Data on Single
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In order to achieve these targets,
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ecycling targets is partly linked t
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31.0 Plastic Bag Bans - Internation
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31.5 Environmental Benefits Environ
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32.0 Levy on Waste Paints - Interna
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The report concluded that total emp
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33.0 Circular WPPR 17/08 - Ireland
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private sector operators incur cost
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the organic waste fraction is no mo
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investments are utilised, will be i
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33.12 Complementary Policies Comple
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34.0 Minimum Recycling Standards (H
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paper/cardboard, metals (aluminium
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England and Wales (United Kingdom)
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householder/small commercial sector
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government is responsible for the w
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Indeed, there are clearly synergies
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strengthened as the increased costs
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from 15.4 % in 1994 to 49.2 % in 20
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materials. 675 Thus complementary p
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34.9 Effect of the Policy on Pricin
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� Strong industrial support via p
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municipality) unless it is composte
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City of Portland, Oregon (USA) The
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waste from manufacturing industries
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solid pre-requisite for the product
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575 However, pending the adoption o
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where the abovementioned statutory
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36.5 Environmental Benefits The env
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Table 36-2 Amount (‘000 tonnes) o
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separated kitchen and garden waste,
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36.9 Effect of the Policy on Pricin
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product, especially when bioactive
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589 risk of contamination with othe
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37.6.1 Environmental Benefits - Pre
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For proposed new composting facilit
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597 • The contaminated batch and
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Table 38-1: Junk Mail Policies Name
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them to increase efforts at suppres
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Table 38-3: Cost Savings from Junk
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39.0 Review of Irish Policy, Constr
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39.1.2 Recycling of C&D Waste - Gen
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40.3 When was the Policy Introduced
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out in national policy and in the i
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currently working in this area and
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goals that are shared by the Nation
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617 waste minimisation and recyclin
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41.7 Environmental Benefits The rev
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to 2 per cent of the landfill levy,
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623 � the name of the accountable
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625 initiatives. In other words, th
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environmental protection and optimu
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The NCDWC had a high level of suppo
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42.15 Lessons Learned For the purpo
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mandatory to varying degrees in Eng
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Japan 635 � Monitoring and auditi
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Hong Kong Industry surveying and in
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Table 43-1: Estimated Total Cost of
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43.8 Social and Distributional Cons
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short time frame over which it has
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In December 2007, Mr. John Gormley,
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647 of waste recovered at the facil
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44.13 Effect of the Policy on Prici
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implementing and managing the Proto
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46.0 Tax on Aggregates - Internatio
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The UK’s ‘Aggregate Levy’ app
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The following study is a comparison
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The intention to implement a landfi
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has encouraged innovation in recycl
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46.9.1 Quality Standards European S
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665 � if one fails to deregister,
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47.0 Product Standards for Aggregat
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It lays down regulations and standa
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has been recognised that recycled o
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48.0 Minimum Recycling Standards (C
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Companies are obliged to either sep
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Table 48-2: Construction and Demoli
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Construction and demolition project
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Belgium Following Article 16 in Cha
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The UK Environment Agency have buil
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during Construction Work came into
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codes. For example, Korea introduce
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In Japan, the lead contractor is re
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50.0 Minimum Recycling Standards (C
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POLICIES FOR RESIDUAL WASTE 693 Int
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695 advance the Commission of their
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have stabilised over the last six y
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ased instruments, or through regula
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Figure 51-4: Materials Captured (re
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200,000 tonnes, though some of this
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tonnes early in 2010, and as much a
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We discuss the matters further belo
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as was made clear above, the inclus
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51.4.2.3 Comment on Targets A conce
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seem that there is little or no bas
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It acknowledges the role of a numbe
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The proposed minimum pre-treatment
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719 The introduction of this measur
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The growing strength of these inter
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It goes on: 723 fully stabilised wa
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of electricity consumption from ren
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52.0 Policies Aimed at Discouraging
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promote cost effective means of res
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authorities work jointly on a strat
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Table 52-1: Summary of Measures by
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It is illuminating to note that in
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737 implemented to make treatment o
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environmental projects, and 45% is
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enclosure; and ii) municipal waste
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52.2.4.4 Finland In 1993, two years
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The objectives of the waste tax are
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52.2.4.10 Country-specific Characte
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meant to finance the Modernisation
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751 - 1995: Publication of a regula
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esidual treatments, and thus exempt
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incineration facilities produce ele
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There are several bands in this tax
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educe the quantity, or improve the
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761 announced in the November 1995
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52.4 Evaluation Studies Available I
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disposal costs necessarily would le
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discernible change in the trend in
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A report on Finnish waste managemen
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some cases, notably in the foundry
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absence of any form of waste tax. F
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Netherlands and Sweden. One might a
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777 ‘the amount of landfilled was
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consequences of an incineration tax
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52.5.6 Reduction in Incineration As
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environmental performance. The land
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increase of between 30-100%. In Aus
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emaining residual waste separately.
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52.11 Evasion and Enforcement 52.11
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Table 52-7: Summary of Measures by
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� A clear rationale for the propo
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overall costs of household waste ma
Page 809 and 810:
53.7 Effects on Technical Change /
Page 811 and 812:
the costs for disposal in municipal
Page 813 and 814:
801 � Old and expired medication.
Page 815 and 816:
Even with high landfill levies, the
Page 817 and 818:
Figure 54-4: Revenues from Flemish
Page 819 and 820:
54.11 Lessons Learned A complex sys
Page 821 and 822:
forge a genuinely ‘autonomous’
Page 823 and 824:
administrations is deemed to change
Page 825 and 826:
The desire to improve recycling per
Page 827 and 828:
Table 55-2: BMW Landfilled in Engla
Page 829 and 830:
55.6 Implementation Costs The inten
Page 831 and 832:
context of UK waste management wher
Page 833 and 834:
During 2007/08, the Environment Age
Page 835 and 836:
823 � Market-relevant information
Page 837 and 838:
need to consider not just ‘policy
Page 839 and 840:
In the above scenario, with capture
Page 841 and 842:
829 figures include nappies, as is
Page 843 and 844:
of the order 65% would reduce the q
Page 845 and 846:
56.2 Proposed Policies to Deal with
Page 847 and 848:
2) Incineration, Incineration, Inci
Page 849 and 850:
Table 56-1: Levies Proposed in RIA,
Page 851 and 852:
839 dramatically reduced by margina
Page 853 and 854:
4) Combustible waste 5) Waste excee
Page 855 and 856:
843 Ew means annual energy containe
Page 857 and 858:
OTHER POLICIES 845 International Re
Page 859 and 860:
57.2 Benefits of Green Procurement
Page 861 and 862:
what can, and what cannot be done,
Page 863 and 864: In light of the renewed EU Sustaina
Page 865 and 866: WRAP WRAP WRAP The greening of serv
Page 867 and 868: 57.4.3 Washington State Recycling a
Page 869 and 870: ecommendation to do so in 2003 via
Page 871 and 872: 859 environment into public procure
Page 873 and 874: has created a ‘level playing fiel
Page 875 and 876: Article 6 of Regulation (EC) No.850
Page 877 and 878: epresentations in relation to this
Page 879 and 880: TARGET SETTING 867 International Re
Page 881 and 882: specific actors, or failing that, t
Page 883 and 884: policy has not been sufficiently re
Page 885 and 886: 873 ban only ensures the best use o
Page 887 and 888: ecent reports from PROGNOS, the EEA
Page 889 and 890: 877 � Separate collection at the
Page 891 and 892: achieves this rate country wide. So
Page 893 and 894: Figure 59-3: Recycling Rates Around
Page 895 and 896: Box 2: Recycling Centres in Upper A
Page 897 and 898: Source: Eunomia (2007) Scoping new
Page 899 and 900: Figure 59-8: Recycling Rates Achiev
Page 901 and 902: absolute terms, i.e. in terms of we
Page 903 and 904: verbrandbaar bouw- en sloopafval”
Page 905 and 906: Figure 59-10: Flanders Residual Was
Page 907 and 908: there does appear to have been a sl
Page 909 and 910: Figure 59-12: Residual Waste per In
Page 911 and 912: 899 • The total ‘better than ta
Page 913: GRANT FUNDING 901 International Rev
Page 917 and 918: authority projects approved for ass
Page 919 and 920: previously been available for such
Page 921 and 922: Table 60-1: Environment Fund Income
Page 923 and 924: een provided are available in the E
Page 925 and 926: additional 10% must be met by anoth
Page 927 and 928: Management Board (CIWMB) provide gr
Page 929 and 930: in place. This is very often to ena
Page 931 and 932: However, earmarking reduces flexibi
Page 933 and 934: 60.8 Approach to Evaluating Effects
Page 935 and 936: There is evidence to suggest that e
Page 937 and 938: 925 � undertaking research on qua
Page 939 and 940: 60.12 Lessons Learned The Flemish P
Page 941 and 942: 929 might be axed in times of fundi
Page 943 and 944: 61.0 Appraisal of Residual Waste Tr
Page 945 and 946: 933 � Biogas for vehicle fuels?
Page 947 and 948: at landfill and incineration, but a
Page 949 and 950: handle. The choice of discount rate
Page 951 and 952: Other key variables of importance i
Page 953 and 954: treatment may give rise to damages,
Page 955 and 956: 1. As described above (for basic st
Page 957 and 958: In addition to these UK focused stu
Page 959 and 960: Table 61-1: Externality Values for
Page 961 and 962: Transport externalities were incorp
Page 963 and 964: arrive at a ‘best estimate’ of
Page 965 and 966:
than greenhouse gases. This is hard
Page 967 and 968:
production, but mainly the much low
Page 969 and 970:
Table 61-5: Summary of externality
Page 971 and 972:
The second report, on the potential
Page 973 and 974:
961 also given the fact that the st
Page 975 and 976:
61.4 Concluding Remarks on the Lite
Page 977 and 978:
965 associated with fuel used withi
Page 979 and 980:
kg kg CO2 CO2 eq. eq. 62.1.1.2 Glob
Page 981 and 982:
These results suggest a significant
Page 983 and 984:
kg kg SO2 SO2 eq. eq. The results s
Page 985 and 986:
62.1.2 Summary of Results In additi
Page 987 and 988:
DALY, DALY, kg kg chloroethylene ch
Page 989 and 990:
This is clearly true, not least sin
Page 991 and 992:
979 � We have used two ‘sets’
Page 993 and 994:
981 includes a dose-response model
Page 995 and 996:
983 assessments is that the blanket
Page 997 and 998:
our analysis, as well as those asso
Page 999 and 1000:
Table 63-2: Emissions Avoided Throu
Page 1001 and 1002:
the Swedish ORWARE model for contro
Page 1003 and 1004:
instantaneous collection rates for
Page 1005 and 1006:
etween 0.1 to 5 l CH4/m 2*h, so tha
Page 1007 and 1008:
include up to 150 substances includ
Page 1009 and 1010:
63.2.2.2 Landfill of Pre-treated Wa
Page 1011 and 1012:
63.3.1.1 Energy Use at Incineration
Page 1013 and 1014:
of a thermal efficiency of 84% and
Page 1015 and 1016:
1003 data obtained from plant opera
Page 1017 and 1018:
Table 63-13: Air Quality Externalit
Page 1019 and 1020:
1007 1. Energy used within the trea
Page 1021 and 1022:
1009 � Optimised biofilter; and
Page 1023 and 1024:
Table 63-18: Results with Low Exter
Page 1025 and 1026:
Table 63-19: Emissions Associated w
Page 1027 and 1028:
metal, the production of which cons
Page 1029 and 1030:
The two processes have similar envi
Page 1031 and 1032:
Eunomia. 1263 The principal climate
Page 1033 and 1034:
Figure 63-1: N-balance of a One Ste
Page 1035 and 1036:
It should be noted that bioaerosols
Page 1037 and 1038:
Table 63-27: Summary of Damage Cost
Page 1039 and 1040:
If the biogas is cleaned of impurit
Page 1041 and 1042:
the source of the natural gas, and
Page 1043 and 1044:
Table 63-34: Summary of Damage Cost
Page 1045 and 1046:
64.0 Costs of Household Waste Colle
Page 1047 and 1048:
Within the following section we ass
Page 1049 and 1050:
in place). It is possible to sense-
Page 1051 and 1052:
Table 64-4: Household Annual Collec
Page 1053 and 1054:
Table 64-6: Interpretation of WRAP
Page 1055 and 1056:
1043 � Refuse collected weekly in
Page 1057 and 1058:
The nature of these authorities the
Page 1059 and 1060:
64.5 Collection Modelling for Irela
Page 1061 and 1062:
ignore, however, is that whilst cos
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