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

Targets such as those in the NBWS should be reflected in the RWMPs, and in
particular, given that the NBWS was completed after the revision of many RWMPs, in
the Annual Implementation Reports on the RWMPs. The NBWS stated:
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Each Annual Implementation Report to be prepared by local authorities on the
implementation of the Waste Management Plan, as required under Key Point
13 of Waste Management: Taking Stock and Moving Forward, should
record progress made in relation to the National Strategy on Biodegradable
Waste over the previous year. The format to be followed in the Annual
Implementation Report will be specified in a Circular letter issued to all local
authorities by the DoEHLG.
Circular WPPR 17/08 states: 114
4.9 Annual Reports on the implementation of waste management plans
should be sent to the Department. In addition, Annual Reports should also
be transmitted to the EPA, so that the information can be taken fully into
account by the Agency when compiling their annual National Waste
Reports. Annex IV provides an outline template of the format of an Annual
Waste Management Plan Implementation Report.
DoEHLG confirms that the Annual Reports which Regions are required to prepare, and
which should reflect targets in, for example, the NBWS, have been received only from
Dublin, Midlands, Mid-west (Limerick, Clare and Kerry) and Connacht. A review of
these reports highlights the fact that the Regions have not, in general, sought to
understand (for example) how much paper and card, or textiles, or organic waste is
being captured in their Region. These are some of the more obviously ‘transposable’
of the NBWS targets, but these have not been considered thus far by the Regions.
In essence, therefore, the requirement to prepare Annual Reports does not appear to
have been fulfilled. When these reports are received, it is not clear what happens to
them in the sense that whether Regions are, or are not, on track to deliver against
their stated plan triggers no form of sanction. Indeed, in those areas where local
authorities have withdrawn from service provision, it is not clear upon whom any
sanction would be made to stick. In short, no one has any specific interest or
incentive to make sure that what they hope will happen will in fact materialize.
5.3.1 The Proximity Principle
The proximity principle is referred to occasionally in respect of regional plans. The
Waste Framework Directive discusses proximity in Article 16:
The network shall enable waste to be disposed of or waste referred to in
paragraph 1 to be recovered in one of the nearest appropriate installations, by
means of the most appropriate methods and technologies, in order to ensure
a high level of protection for the environment and public health.
114 DoEHLG (2008) National Strategy on Biodegradable waste: Implementation of Segregated “Brown
Bin” Collection for Biowaste and Home Composting, Circular WPPR 17/08 to each City and County
Manager, 31 July 2008.