An Taisce welcomes the commencement of a preparation of Regional Waste Plans and would like to make the following comments which we request the local authority take into consideration in the finalisation and adoption of the plan. We would also request that the local authority make An Taisce known of any further consultation periods regarding the making of this plan and issue An Taisce with notification of any future proposed amendments to the draft plan and notification of the final adopted plan.

Introduction and Preliminary Comments

One of the key issues addressed in the Government's most recent waste management policy document, A Resource Opportunity – Waste Management Policy in Ireland (July 2012), is waste management planning; and the policy reminds us that waste management planning has been a statutory function of local authorities since 1996. Under Section 22 of the Waste Management Act, 1996, local authorities were given the discretion to come together to discharge their waste management planning functions in groups, as a result of which ten Regional Waste Management Plans were drawn up and implemented. This shared service approach appears to have worked reasonably well, even though we consider that most of the waste management plans were lacking in any real incentives to eliminate waste, to reduce waste, or to encourage repair, re-use and re-cycling. To date, we have a situation where almost all of Ireland’s recyclable materials are exported, with very little re-processing or recycling carried out in the country. Nevertheless, the implementation of the regional waste management system could be said to have brought about an improvement, primarily as a result of European Union Directives and a strengthening of the Environmental Protection Agency’s role in waste prevention and management.

The existence of waste management regions, within which each region was expected to become self sufficient in waste-related infrastructure, so that transportation of waste across regional boundaries would be minimized, did not appeal to the waste management industry, members of which felt strongly that waste should be transported to wherever it could be disposed of more economically. In most cases, this approach resulted in waste being trucked long distances across the country to landfill sites where the gate fees were less than at other more proximate sites. As a result of this lobbying, the boundaries of the waste management regions became more “permeable”, especially in Leinster, where large quantities of urban and industrial wastes from the expanding Dublin metropolitan area found their final resting place in Counties Meath, Wicklow, Kildare, Louth, Offaly, Cavan and Westmeath. Some wastes may even have travelled to counties further away; and there is every likelihood that wastes generated in other cities such as Cork and Limerick were transported to other counties for landfilling.

The recent policy document, A Resource Opportunity – Waste Management Policy in Ireland, appears to have taken this move a step further, and is proposing a reduction in the number of waste regions from 10 to 3 (section 3.4, page 28). This is described as the result of “local authorities undertaking their waste management planning responsibilities, guided by the programme of reform of local government structures”, but perhaps it could be more correctly stated as the result of a policy set by the Department of Environment, Community and Local Government. In response to this policy change, a limited form of public consultation has been advertised, in which written submissions may be made to the Regional Waste Coordinator in the relevant Local Authority.

Download the submission here.