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Submission relating to the Draft Document for the National Strategy on Biodegradable Waste for Cré - Composting Association of Ireland Teo

Introduction

Waste management is a whole system, integrated in every aspect of society from the production of goods (and packaging) by manufactures and generation of waste by consumers to the system that collects and processes waste. In a perfect world, there would be no such thing as waste. Aiming towards a zero waste society would affect and improve many areas of national policy from economic development and energy management to environmental protection.

There are many choices and options for dealing with waste. These are outlined in the following policy documents: Changing Our Ways (1998), Delivering Change (2001) and Taking Stock and Moving Forward (2004) as well as the regional waste management plans developed and adopted by local authorities within Ireland. The over reliance on landfilling valuable materials is no longer sustainable… practically, politically, economically and environmentally in Ireland. Therefore, alternative methods have been identified and some are beginning to be implemented throughout the country. These documents provide a menu of options for local authorities within waste management regions to pick from. The National Biowaste Strategy provides the opportunity to select a set of options and form them into an integrated program or strategy for dealing with biodegradable waste.

Cré believes that intensive source separation is the key to the success of a strategy to effectively utilise materials here in Ireland while minimising waste management costs at all levels, maximising diversion from landfills and protecting the environment. We believe that if materials are separated into individual components, they can be recovered and processed to create safe products with market value. So what would a strategy based on intensive source separation look like?

1. At a minimum, all residents and business would be given the opportunity and financial incentive to source separate into at least two streams, one for wet biowaste (food and green wastes) and another into dry waste. A three stream collection of dry recyclable waste, biowaste and residual grey bin waste would also be acceptable if all generators are encouraged to participate. This opportunity to recycle would be provided via drop-off centres for rural residents and via kerbside collection for urban residents. All businesses would be provided the opportunity to participate in a kerbside collection program with a two or more stream separation system. The goal would be to encourage or

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require all residents and businesses to participate in source separation and for local authorities and private hauliers to provide the services to collect the source separated materials.

2. Paper and wood would be separated from the dry waste stream at material recovery facilities and to the maximum extent possible sold into secondary material markets where paper is remade into paper products and wood would be made into fibre board. For low grade paper and excess wood, a fuel market can be tapped. Here these clean “biofuels” could be used instead of peat briquettes for home heating or as a fuel for electric power generation in existing peat burning power generating plants. This would be in essence a fuel substitution program replacing non-renewable peat with a cleaner renewable biofuel made of compressed wood and paper briquettes or pellets.

3. Wet Biowastes or food, green waste, sludges and some wood and paper would be handled using biological treatment methods, both aerobic composting methods as well as anaerobic digestion methods to produce energy. This would convert these BMW materials into a high-quality soil amendment that could be sold to gardeners, landscapers, local authorities, contractors, nursery growers, golf course operators and farmers.

To make the system easy to implement, new landfills would be required to provide space for material recovery and biowaste facilities so that the handling, processing and transfer of waste materials can be most efficient. Equipment can be shared and operating costs can be minimised.

Cré believes that a BMW strategy based on intensive source separation and maximising use of material markets for paper and wood, biological treatment for food and green wastes and fuel substitution of clean biofuels for non-renewable peat in existing power generation facilities would enable Ireland to meet its BMW diversion goals without building more expensive MBT or mass burn energy recovery incinerators.

Since BMW is the largest segment of the waste stream (two-thirds of the waste) and creates most of the environmental impacts associated with landfilling (odour, methane gas, water pollution), the BMW National Strategy can drive the development of the entire MSW system in Ireland, from beginning to end. This means that if all biodegradable waste can be diverted from landfill disposal, lanfilling becomes a safer and less expensive disposal option compared to MBT and Energy Recovery Facilities. An intensive BMW National Strategy solves most of Ireland’s waste management crisis today that is cost-effective, environmentally sound and a solution most likely to be accepted by communities in Ireland. This strategy, on an island wide basis, would concentrate on maximising recycling and reuse of materials within Ireland.

The National Strategy also creates an opportunity to lead politically within an expanded Europe by showing how a problem can be quickly turned into a solution. Building on some of Ireland’s past public policy successes (plastic bag levy, smoking ban), Ireland would be in a good position to show how a smaller country within the EU can develop an

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innovative, cost effective and sustainable method for managing its waste. The idea would be to turn a societal cost into a tool or engine for local economic development. Framework

Now is the time, before implementation of the regional waste management plans are fully underway, to create some standardisation of service levels, financial incentives, public education initiatives and manufacturing standards for industry so that cooperation can be maximised, costs can be minimised and there is a truly seamless and integrated system to reduce and reuse waste in Ireland. This type of system would not be reliant or depend on export markets for recyclables or MBT plants or mass burn waste incinerators for the success or failure of this strategy or system.

The National Strategy has the opportunity to create a bold new vision and set the stage for the implementation of creative set of new ideas to develop a unique solution for Ireland. The national strategy has the opportunity to lead Ireland toward being a zero waste society.

Goals for Ireland’s green “waste” system:1. Maximise reduction in production and generation of waste by industry 2. Level off, then reduce per capita generation of waste to reduce size of overall

waste management infrastructure. (fewer landfills and processing facilities, fewer trucks on the road, reduced waste management costs for the end user).

3. Minimise costs: to government, industry and consumers4. Protect the environment: air, water, land5. Keep it simple and make it convenient6. Maximise recycling to reduce materials going to landfill7. Use recovered materials to create economic development opportunities in Ireland 8. Reduce reliance on export markets for recycled materials

The waste system in Ireland consists of the following players: Producers: manufacturers and industry Generators: residents, institutions, government and businesses Operators: collection/transfer, processing, disposal (markets or landfills) Consumers: individuals and organisations

The following provides some ideas about the framework for a BMW National Strategy, breaking up discussion around potential strategies and public policy options around the players or target groups mentioned above: producers, generators operators and customers. After that, specific comments on the Draft Strategy Report are provided.

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1. Producers: manufacturers and industry

Role: Producing, importing and distributing goods and services

Goals: Reduce production of waste by manufacturers and industry going into the island’sconsumption system

Encourage production of goods made from recovered materials

Policy Options:-encourage reduction of packaging, double packaging by industry-encourage use of reusable packaging and shipping trays/boxes-encourage production of recyclable or compostable packaging-discourage or ban production and use of non-recyclable packaging and products-create or enforce producer responsibility regulations: if the product or packaging

cannot be recycled or composted, the producer needs to take it back for reuse or recycling (batteries, electronic goods, multi-material goods, printer cartridges, you name it)

-encourage use of recovered materials into production processes-encourage creation of new businesses to use recovered materials-provide R & D assistance to academic organisations and industry to develop new

products and production processes to accept recovered materials and make products for the Irish market

Specifics:This would entail the greening of Irish Industry from reducing the production of waste to creating business opportunities to use recovered materials in manufacturing. Instead of becoming a waste disposal problem, BMW materials could create business opportunities at the community level and contribute to economic and job growth. The emphasis would be on how to use these materials locally to create value within the national economy. Here are some specific ideas about which BMW materials could be made into specific products that could be made, sold and used in Ireland:

wood and low grade paper could be made into fireplace briquettes, a lower polluting log than peat briquettes reducing air pollution and peat extraction in Ireland

low grade paper could be made into insulation products helping to reduce energy consumption and the island’s dependence on imported oil

micro paper plants to produce moulded paper packaging products or box board low grade paper into animal bedding- its more effective than straw or saw dust

and can be composted after it is used non-reusable textiles can be made into cleaning rags and sold back to industry in

Ireland or made into reusable nappies. biowaste can be made into high-grade compost to produce a soil amendment,

topsoil, potting mix or fertiliser product reducing the need to import and use

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potentially toxic chemical fertilisers and pesticides and reduce the extraction of peat in Ireland.

With this strategy, Ireland has created a market and use for two thirds of the waste stream. What’s left, plastic, metal, glass and mixed materials can be dealt with in the same way. The question being, how can we use it here in Ireland? Glass can be ground up and used in road construction, plastic can be made into building materials and metal can be sold in high value recycling markets. All together, 70-80% of the waste stream is recycled eliminating the need for more expensive MBT plants and energy recovery facilities.

2. Generators: residents, institutions/government and business

Role: These are the consumers of goods and services within a community or nation and produce waste as a result of their work activities or life at home.

Goals: -reduce generation of waste

-make it convenient to recycle-keep waste management costs down-get everyone to source separate waste materials and participate in drop-off or

kerbside collection programs

Policy Options:-encourage waste reduction and minimisation

-home composting-thrift shops, repair, clothing banks-reusable packaging -bulk purchasing

-create financial incentives for collection and at the point of disposal-require mandatory participation-conduct massive public education at all levels-provide drop-off and kerbside services available to everyone-impose penalties for burning waste, fly tipping

Specifics:This set of policies and programs would encourage residents, institutions, government agencies and businesses to reduce waste generation and to participate in community based collection programs for source separated materials. This will require a significant amount of change from current practices. But by making it easy and less expensive, the generators will be more motivated to participate. If a voluntary system does not work, mandatory service and/or participation could be required.

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3. Operators: Local authorities operating collection systems and disposal facilities and the waste management industry:

Role: Develop and operate waste collection, processing and disposal infrastructure in an efficient and cost-effective manner while protecting the environment.

Policy Options:-set minimum collection service requirements for urban and rural residents and

commercial accounts -wet/dry or three bin kerbside collection service mandatory for all business

generators and urban residents-ban organics from grey or black bins-encourage development of community based and regional biowaste composting

facilities-encourage development of community based and regional material recovery

facilities-provide sufficient funding to both public and private initiatives that are consistent

with developing and implementing this strategy- programmes as well as collection system and processing facilities

-set process and product quality standards for recycled products

Specifics:In this segment of the system, a national standard for collection service would be created so that all generators are provided a convenient and easy-to-use collection service. The operators provide the service and encourage generators to participate. Participation can be encouraged through the use of incentives (financial, technical assistance, public education, ease of service) or it can be mandatory.

Serious consideration should be made to implementing, at a minimum level, a wet/dry collection schemes through out Ireland for all generators. In essence only two collection bins are required, one for organics (food and garden waste) and the other for all other materials. Once the putrescibles (food and green waste) are removed from the waste stream, all other waste can be easily sorted (disposable nappies would need to go into special thick coloured bags so they could be sorted out easily, but then again, disposable nappies could be banned in Ireland). The two bin wet/dry collection is easier for the generator, takes less space and costs less than three bin systems. The same truck can service both streams. Residentially, wet and dry collections could be staggered every other week. Commercially, service can be provided as needed.

The processing infrastructure would be quite simple. Every region would have its biowaste composting facilities for the source separated organics and material recovery facilities to process dry waste or dry recyclables. If everyone is required to participate and service is provided to all generators, all waste goes to either a biowaste facility for composting or a material recovery facility for sorting. No waste would go to a landfill

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without prior processing. The wet/dry strategy can divert up to 75-80% of MSW from landfill disposal by removing all BMW waste from the waste stream (2/3rds of the waste stream) and by recovering glass, metal and plastic at the same time. The waste that is left over has very little fuel value and is, for all practical purposes, inert for safer landfilling. What this really means is that expensive, potentially polluting and politically unacceptable mass burn energy recovery incinerators are not needed unless this strategy fails.

4. Consumers: individuals and organisations

Role: Purchase goods and services within an economy

Policy Options:-develop and sponsor buy recycled initiatives and campaigns-create demonstration projects to highlight success stories-educate procurement personnel about recycled products-encourage or require local authorities and national government departments to

buy recycled and to specify use of recycled products in government contracts

-reduce or eliminate the VAT rate on sale of recycled products-educate consumers about quality standards in place -stimulate media coverage of community success stories to encourage people to

participate in source separated collection schemes and buy-locally produced recycled products

-set up government market development commission or agency to promote products made from recovered materials.

Specifics:The consumers are also the generators, but the consumer side of the equation is an important one to close the recycling circle. It creates the demand in the marketplace to pull the recycled products through the economy. Quality control measures will need to be in place to assure that products are both safe and better than products made from raw materials or mined from non-renewable sources. The public education element of this effort cannot be underestimated or under funded. The new waste system needs to be integrated into people’s everyday life and it must become habit and second nature to everyone that lives and works in Ireland. The message of public education efforts and outreach would be that waste materials need to be recycled so they can be reused here in Ireland to create jobs, reduce pollution and protect the environment.

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Specific Comments on Draft Strategy Report

The following comments will be linked to page or section of the Draft Strategy Report

Page 1: Strategy AimsA discussion of program goals would be useful in this section and include the goals listed in the introduction of these comments on the top of page 3.

Page 1: What is biodegradable Waste?This should include wood. This is a larger portion of the waste stream than reported. Broken pallets, wooden boxes, crates and spools as well as wood from construction and demolition work generates a lot of wood waste. This can be 5-10% of the entire waste stream.

Page 4: Table 2.1 Biodegradeable Municipal Waste Generation, 2001This table should be titled BMW generation, recovery and disposal. A column at the end should be added to show the recovery rate for the selected items with a total for all combined:

Paper and Cardboard 21% recovery rateTextiles 4% recovery rateOrganic Waste 7% recovery rateWood 85% recovery rateBMW Total 16% recovery rate

Page 4: 1995-2001 Muncipal Waste TrendsSummarising from the chart it would be interesting to see the growth rate of waste generation versus the growth rate for recycling. This may show a positive trend that the growth rate for recycling is faster than the growth rate for waste generation. Things are heading in the right direction. The main point to be made here is that the total amount of materials going to landfill is by far outstripping the increase in recycling, 600,000 tonnes of increased landfilling versus 200,000 tonnes of additional recycling. It is not clear if the figures here represent an annual figure or cumulative one over the 6 year period mentioned.

Page 6: Material Recovery Facilities and Biological Treatment FacilitiesAn updated chart showing facilities in place as well as facilities in the planning stage would help identify the gaps for service per region for MRFs and biowaste facilities.

Page 7: Thermal Treatment FacilitiesIf the Dublin facility is planned for 400-500 tpa, we would all be happy. Wouldn’t this represent a tonne per day figure?

Page 8: Projecting Waste Growth

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Waste growth can be tied to many factors, all mentioned in the report. However, it would be unreasonable to predict waste growth based the boom times of 1995-1998. Economic growth has slowed since then. It might be useful to chart waste growth under a lower growth scenario at 2% per year.

Page 8: Gap AssessmentIt might be helpful to put in a biowaste, wood waste and paper recovery base line along the bottom of the chart to show where we are and where we need to be. The chart shown assumes that there is no past or current recovery. This has been growing and it would be interesting to see its growth curve over the last few years compared to the generation growth line and to show where we are now and where we need to be in 2006, 2009 and 2016. Would this gap analysis change if we factored in the recommendations of this strategy? How would it change?

Page 9: Table 3.2 Gap Analysis- Total Treatment Capacity RequiredThe number of 440,000 for 2001 does not match the total from Table 2.1 of 233,852 for Recovered BMW generation 2001.

Page 9: Regional Gap Assessment, Table 3.3It may be useful to add two columns to the chart just left of the column for 2006 gap. One column could summarise existing BMW plant capacity within a region and another column could summarise planned facilities according to what is in the planning or EPA licensing process to give a better idea where the gaps are per region.

Page 10: Integrated Mix of Treatment OptionsWe believe that MBT plants would be preferable, less expensive and accepted by the community more than mass burn energy recovery facilities. Ireland should be given a chance to manage its waste without building new dedicated incinerators just as the power industry in Ireland is generating electricity without the use of nuclear power plants. Watch regions over the next five years with their plans and see if they are really needed at that point.

In the last paragraph, the first sentence does not make any sense. “Finally, all countries with high diversion rates use thermal treatment for a considerable proportion of traditional mixed waste collection of BMW.” Shouldn’t it be mixed waste disposal of BMW instead. Even so, high diversion rates are also achieved without incineration. Look at Austria, parts of Germany and the west coast of the U.S. Diversion levels of up to 65% of the entire waste stream are achieved without the use of MBT plants or dedicated mass burn energy recovery incinerators.

In addition, before such a claim is made, that mass burn incinerators are needed to reach the BMW diversion goals, how do we know that this strategy is the most cost effective way of handling waste in Ireland? An economic analysis of the entire system needs to be presented and argued to show how much a strategy costs, in terms of capital costs, operating costs and operating revenues. For example, what is the cost of building and operating the following systems or strategies:

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a) voluntary source separation with biowaste and material recovery facilities followed by MBT and landfilling of MBT residuals.

b) voluntary source separation with biowaste and material recovery facilities followed by mass burn energy recovery incinerators and lanfilling of ash.

c) intensive source separation with biowaste and material recovery facilities followed by landfilling of contaminants from the biowaste facilities and rejects/residual waste from the material recovery facilities

Our recommendation is to follow the EU’s waste hierarchy and introduce intensive separate collection of BMW from all generators and provide the infrastructure for recycling these materials in each region before MBT or mass burn incinerators are considered.

If the system is designed so that all waste material either passes through a biowaste facility or a material recovery facility then the BMW diversion goals can be reached without having to add another layer of expensive processing technologies. In all cases, a landfill is needed for residuals or ash anyway. However we advise that landfill taxes remain high which will encourage producers of BMW to look towards other ways of dealing with their waste.

Ireland may be so successful with its intensive source separation program that MBT and mass burn energy recovery facilities may not be needed. This would save the country €100-200 million in capital cost alone. Why build four layers of infrastructure when three will do.

Page 11 and throughout the documentWe would recommend changing the formatting of the document to allow the enlargement of charts. They are just too small to read. The two column format may be changed to a one column format with an executive summary in a two column format for ease of reading.

Page 12 Market DevelopmentAn aggressive policy on product development should be pursued, while the growing media industry can use moderate quantities of high quality and consistent compost, the amounts will not make a significant dent in the targeted rate of compost to be produced in Ireland. Bulk amounts of composted material could be used for horticultural, cereal crops and turf industry if specific products are developed for this purpose.

Page 13: Section 5.3: Establishing TargetsIn the third paragraph, the 306,000 of current BMW processing capacity is for which year? This is not consistent with numbers presented for 2001. What would be most helpful is to provide an idea of the amount of capacity that would be need to be put in place to meet the interim targets on an annual basis. This ties in with the Gap Analysis.

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Page 14: Table 5.1: Proposed BMW Diversion Targets (tonnes)There is a typo in that total diversion adds up to 75% instead of the 76% listed. It also might be useful to match up the total amount of BMW generated for the target years and project a recovery rate for each material so you can set goals and then track diversion rates by material type. All of these numbers can be confusing. In Table 2.1 it shows that total gross BMW is 1,491,272 for 2001. In Table 5.1 the total gross BMW is 2,342,432 tonnes for 2009. In eight years that is a 57% growth rate. This goes back to the growth rate assumption. Would this be reasonable or will generation peak and start to decline.

If you project the numbers out from Table 2.1 to get an estimate of what is generated in 2009, then the tonnes diverted in Table 5.1 can be taken out and matched with a material type. Therefore with 1,262,930 tonnes of paper and 706,082 projected for recycling, that is a 56% recovery rate for paper. If 907,708 tonnes per year of biowaste are projected for 2009 and 424,788 are processed by biowaste facilities, then this represents a 47% recovery rate for green waste and food. The same can be done for textiles and wood.

Lastly, in relation to Table 5.1 in particular, we are not sure what some of these numbers represent. Is the assumption that all residual waste would be thermally treated with ash going to landfills or some waste thermally treated with ash and untreated waste going to landfills? Since 25-40% of the materials incinerated become ash, it will be important to account for this when the numbers are totalled. For example, does the 641,681 tonnes projected for thermal treatment in 2009 represent the net number of tonnes processed (total input minus ash) or the total input of materials? Likewise, does the 569,881 tonnes of landfill materials include the 100-200,000 tonnes of ash from the thermal treatment plants? If not, the numbers need to be adjusted.

Page 14: Section 5.4 Food and Garden WasteWe commend the Department on the optimistic recycling rate of 40% for home composted green waste and hope this can be achieved over time.

Page 15 and thoughtout on MBTThere has been a lot of interest and a lot of activity in this area by the private sector. Oxigen, Thorntons, Mr. Binman, Mulleady and others are already processing or are considering processing mixed waste to mechanically separate out the organic fines for composting. We are talking about roughly 100,000 tonnes/year of material already being processed. There needs to be some serious thought given to how this strategy would work. During a transition to intensive source separation, MBT plants could be built and then converted to source separated plants when these materials are collected from generators. To facilitate siting, permitting and EPA licensing, these facilities could be installed on existing and planned landfills. Most EPA licenses already include the provision of some biological treatment in red lined areas within the sites. This fact alone should drive this strategy into implementation faster than any other and provides permitted and licensed sites throughout Ireland that are ready to be built and operated. In

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other words, this strategy has potential to have an immediate short term impact and would be easiest to build and integrate into Irish society.

Pages 16-17: National Waste Prevention ProgrammeThe idea of public procurement policies (second and last paragraphs in section) is a market development tool rather than a waste reduction tool. We also feel that the promotion of bulk purchasing by residents and businesses can have a significant impact on reducing the volume of packaging waste.

Page 17: Pay as you Throw SchemesWe support this policy as a way to encourage participation. In the last paragraph in the left column, there is a typo in the fifth line. The word “being” should be replaced with the word “been.”

Page 17: Home CompostingCré believe it is important to stress the importance of home composting in any BMW strategy as home composting will definitely have a role to play in reducing the amount of BMW requiring collection and processing.

Home composting also teaches people about composting… the biology, the process and the product. This makes it easier to site and get planning permission for centralised facilities because people are familiar with the process and it makes it easier to market and sell the final products because people understand the value of and how to use the final compost product.

However, there is a need for local authorities to play a role in encouraging home composting in their area and provide information to residents on how to do so. Interest has definitely increased in the home regarding recycling especially in light of the introduction of Pay as You Throw Fees.

Page 18: Reuse of TextilesLocal production of rags or nappies may be a nice micro industry that could be developed for Ireland to convert this waste material into a sustainable business venture. Rags could be exported to Britain if supply exceeds demand in Ireland.

Page 19: Recycling of Paper and Cardboard It is important to target all clean paper for recycling including junk mail, office paper and box board (e.g. cereal boxes). If the paper grade cannot be sold in material markets to generate a return, then it can be processed into a fuel product for co-generation purposes (burning with or instead of peat).

Page 19: Collection Methods for household paper chartThere are many successful examples of providing kerbside collection services to multi-storey households. In essence, a drop-off centre is placed in the parking lot for residents to use. This makes it easier to participate and increases recovery of recyclables. The point

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is that multi-storey households represent a large portion of waste generated in urban areas and there needs to be a more convenient service to accommodate this sector. A two bin wet/dry system could be offered and would take up less space than a three bin collection system.

Page 20: Tables 7.3 and 7.4The capacity required in Table 7.3 of 673,430 does not match the MRF capacity of 735,000 in Table 7.4

Page 21: Biological Treatment of Food and Garden WasteIf all generators are provided with drop-off or kerbside collection services, then a larger percentage of food and green waste can be recovered than the 45% target for 2009. With the improvement of the collection infrastructure to provide source separated collection for food and green wastes, 80-90% of residential food and garden waste could be diverted to biowaste processing facilities. As indicated earlier, a 40% contribution from home composting is overly optimistic where a 10% diversion rate would be more achievable even under the most aggressive of programs.

Page 21: Section 8.3 Collection SystemsWe feel that is will be very important to define or set a minimum level of collection service for rural and urban areas. This means that urban areas need to be defined as towns larger than 1,000 people? Minimum service levels for residential waste could be the following:

a) Rural Areas: Network of conveniently located drop-off sites to collect source separated paper, cardboard, wood, green waste, food, glass, cans and plastic.

b) Urban Areas: minimum of wet/dry kerbside collection service for all urban residents including single family as well as multi-family households.

For commercial accounts (businesses, institutions and government) a minimum of wet/dry kerbside collection service would be required for all businesses regardless of location. Local authorities would be encouraged to exceed these minimum service levels as in Waterford County were all residents will be provided with wheelie bins for biowaste collection and special bags for dry recyclables.

Page 22: Table 8.2- Collection methods for Food and Garden Waste from HouseholdsWe do not see why kerbside collection cannot be extended to multi-storey households. A simple wet/dry system could capture paper in the dry bin as well as green and food materials in the wet bin.

Page 22: Section 8.3.2 CommerceSmaller commercial accounts (less than 50kg/week of food waste) can be provided with wheelie bins and collected at the same time as residential wheelie bin customers. There are a lot of small businesses in Ireland so this can add up. The basic point here is that if the collection system does not target all of the generators, then the recovery program will not be as successful. The aim should be to provide the opportunity to recycle to every

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generator including multi-storey households and small commercial generators. The question here is: why set up an intensive source separation program and then give a lot of the generators an exemption not to participate in the program? It seems like we might not be taking full advantage of the investments to be made in developing the collection and processing infrastructure. With more tonnes pushed through this system, the cost per tonnes drops and the entire system is more cost-effective. The bottom line is that everyone needs to participate. It has to become a part of everyone’s life at home and at work.

Page 22: Section 8.4 Biological Treatment CapacityIn the first paragraph, the current operational capacity of 60,000 tonnes per year does not match the numbers in Table 8.1 that show a capacity of over 22,000 tonnes/year in 2001. Since the 60,000 tonnes per year includes the composting of sludges, should this number be included? An updated map and table of existing facilities as of 2003 would help put a more realistic figure on the current level of capacity in Ireland.

Also, BMW can also be successfully co-composted or co-treated with sludges or biosolids from municipal waste water treatment plants.

Page 23 Animal by-Products RegulationThe conditions applied in the Animal by-Products Regulation have been generated from an animal health point of view rather than a compost product or waste management perspective. The difficulty in meeting the regulation requirements may have the effect of driving catering waste away from composting facilities and back to landfill. The cost of composting according to the Animal by-Product regulations should not exceed the cost of sending the product to landfill. There is a need for standardisation of the regulations across Europe as some countries have adopted strict regimes where others have been more lenient. Achieving a temperature of 70°C should occur when the organic matter has been stabilised to some extent as then it is less vulnerable to re-infection in contrast to fresh organic material.

Page 24: Section 9.2 Current StatusWith what is in place by a few major waste management companies, the 30,000tpa figure for mixed waste processing is underestimated. The figure may be closer to 100,000tpa.

Page 25 Mechanical Biological Treatment The resulting product from MBT should not be called compost. A compost with high heavy metal content and high levels of foreign materials may not be suitable even for landscaping. There is an urgent need to develop standards to determine the stability of MBT for landfill application in order to significantly reduce greenhouse gases e.g. methane.

Page 27, 28, 29, 32 Separately Collected Biowaste Separately collected Biowaste is essential to produce a quality compost product low in heavy metals and impurities. Research has consistently shown that heavy metal

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concentrations are lower in source separated compost. In fact, a Cré study in 2003 into ‘The Quality of Waste Derived Compost in Ireland’ showed that Biowaste compost contained significantly lower concentrations of heavy metals compared to other European countries such as UK, Germany and Austria. Ireland could take the lead in Europe and produce compost of the highest quality. However this will only be achieved through separate collection systems for biowaste and continued education and awareness programmes.

Page 28: Colour Coding of Waste Recycling CollectionsWe strongly support a simple wet/dry two bin collection system for all MSW in Ireland with some communities choosing a three bin system. A mix of the two systems can be adopted with three bins for residents and two for businesses. However, the two bin system for all generators can reduce collection costs, increase overall recovery and save space in urban areas and in multi-storey households. Too many bins can create confusion and discourage participation by making recycling unnecessarily difficult and complex.

Page 31: Section 12.1.3 Disposal of organic waste to foul sewerIt is important to note that the cost of adding sufficient waste water treatment capacity to handle food waste would be more expensive than setting up biowaste composting facilities to handle the same amount of material.

Page 33: 13.2.2 Government-led Initiatives Irish Compost StandardsMinimum standards should be considered at an EU level but standards for producers should be developed by industry and the member states, for example standards of heavy metals for nursery plants will be different to standards for food crops of organic growers. The Chairperson of the Technical Committee of Cré is already involved in developing standards at a European level. Financial support should be made available from the Department of Environment to develop these compost and analytical standards fro Ireland. It is not just a question of copying the English standards, but these may be used as a template.

Page 33. 13.2.2 Irish Compost StandardsStandardisation of sampling and analysis is essential if markets for products from composting are to be developed. The Horizontal project and the CEN TEC223 WG4 group are undertaking standardisation at present at a European level, however no standards are being developed at a national level at present as stated in this document.

Page 33. 13 Market DevelopmentMarkets should be developed for the use of composted green waste for ‘organic’ production. Organic production has shown massive growth in the past 5 years and offers a potential to large scale use of composted biowaste. Markets need to be developed in the horticultural and cereal sector.

Page 34: Market DevelopmentThe market development report produced by the EPA misses a few key market opportunities that have proven successful in the US, Canada and other European

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countries. These include the professional landscaping market, home gardening market and the construction industry market for compost based products, including pure compost soil amendment, course mulches for erosion control, topdressing for lawns, topsoil and potting mixes. In some communities, these provide the entire market for compost made from regional or community-based biowaste composting facilities. Compost can also be used in organic farming which has shown massive growth in the past 5 years and offers a potential to large scale use of composted biowaste.

Page 34 Peat Replacement Policy: Producer Responsibility InitiativeThe public sector should encourage the use of compost but not as a complete substitute for peat, but as a diluent in peat. Composted Biowaste material without dilution with a material such as peat cannot be use as a growing medium.

Page 34 Development of Horticultural, Agricultural and Forestry Markets/Nitrate

Rate of application of composted materials to soils: - The use of stabilised Biowaste at an application rate of 200 tonnes of dry matter per hectare over 10 years .(EU Working Document 2nd Draft Biowaste Directive) was probably based on sewage sludge application and needs changing Sewage sludge has a high N content and nitrogen is readily available. Composted Biowaste and particularly composted greenwaste has a low N content. Depending on feedstock and stabilisation it releases nitrogen very slowly and there is no danger of nitrate leaching. In fact with partially stabilised composted greenwaste it can soak up the pool of nitrogen in soil. In addition, nitrogen availability from sewage sludge can be reduced by mixing it with partially stable composted greenwaste. In any case tests should be developed urgently to predict the release or immobilisation of N and carbon when composted greenwaste is added to the soil. Some progress has been made in this area in France. Application rates of compost should be based on these tests and not on an empirical basis of 200 tones dry matter per hectare over 10 years. These low rates will have minimal or no affect on soil properties or nitrogen levels.

A great deal of progress has been made identifying the beneficial effect of composted greenwaste on soil physical properties. However at the rate of 20 tonnes of dry matter per year the application will be only 4mm of compost if it was applied on the surface of the soil. This very low rate will not have any significant effect on the soil physical properties. Similarly different soils have different bioavailability of heavy metals clayey soils have lower availability than sandy soils, this should be taken into account when application rates are being calculated, application rates will need to be site specific.

In view of the above, consideration should be given to re-examination of this policy of low rate of compost application on farm land.

EU Nitrate Directive 91/676 EECWater Framework Directive 2000/60/EC

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Page 35: Table 13.3 Summary of Compost Market Development ActionsIt seems that the time frame for many of these activities are a bit ambitious especially given that 2004 is almost half over and the Draft Strategy has yet to be revised and adopted.

Page 36: Markets for Paper and CardboardEmphasis needs to be placed on using export markets for high grades of paper when they can be reliable and generate income. If not, market development activities need to focus on building up the local capacity to convert these materials into products that can be used in Ireland, including

-insulation-animal bedding-moulded paper products-tissue paper products-and lastly as a substitute fuel product

Page 37: Implementation and MonitoringThere needs to be a clear action plan and timeline for government action. What will the national government agencies be responsible for and when and what will local authorities be responsible for. The national government action plan would include activities related to standard development, minimum collection service standards, funding, policy development, procurement policies, etc.

Page 39 Recommendations for future waste planning Community composting, such as is carried out by farmers in Austria should be encouraged. Regulations should be somewhat flexible to encourage this type of composting.

Not addressed: Labelling requirementsThe most important parameters which should appear on the bag are feedstock, level of maturity (to assess application) and rate of dilution with a low nutrient component. It is of importance for the success and safe use of compost that information on the application rates, ideal use and properties are shown clearly.

Not addressed: Compost Standards Process requirements:The idea of ‘residence time’ (i.e. the amount of time taken to compost material) should not be a criterion to determine the stability of compost-with improved process control the residence time of composting can be greatly reduced. Stability tests would be more relevant and useful to define if the compost is ready for a particular use. This is being researched as part of the EU horizontal project and by CEN TEC 223 WG4.

Other process control requirements have not been addressed such as odour and bioaerosol measurements.

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Spelling error: page 34: ‘growing trails’ should be changed to ‘growing trials’In Summary

The draft report is a good start and summary of available options and we support the activities recommended to set up a collection system to process source separated materials. We feel that there is so much potential here. This report could be a really exciting driver of public policy around waste, energy, economic development and the environment. The report might be missing an opportunity to tie waste management into other critical public policy areas. When we talk about integrated waste management we often think of the system itself. But it is also important to integrate it into the society and culture of Ireland, sort of a system within a system. That’s what makes this issue particularly challenging yet potentially rewarding. It’s a mind shift, we are dealing with resources here and the challenge is how do we most effectively use them here in Ireland.

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