The Plan dismisses Scenario I (No Incineration, 48% recycling of Household Waste) because it fails to reach a 50% rate of household waste recycling. This conclusion is flawed as examples abound of where over 60% recycling is being achieved today. It is an indictment of the authors of the Plan that it fails to deliver more than 48% recycling. When this point was put to the authors of the Plan at the recent public debate, their only response was that this "is a 5 Year Plan". Considering that the Plan is recommending an investment in an incinerator which will have to be repaid over 20 years, that is not an acceptable answer.

The Plan states that there will be a residue of 25% grate ash from the material incinerated to be landfilled, which for the proposed 184,000 tonnes of material to be incinerated, would be 46,000 tonnes/annum. Yet the Plan states that the amount of ash to be landfilled to be 7,356 tonnes. No explanation was given at the recent public debate for this discrepancy.

The Plan reaches a conclusion that Scenario III (Incineration) has a lower environmental load than Scenario I (No Incineration). This conclusion is flawed, since it is based on grossly understated environmental loads caused by emissions of Carbon Dioxide from the proposed Incinerator, and overstated impacts on the environment of the Methane emissions from the landfills. Again this point was put to the authors of the Plan at the recent public debate, but they were unable to explain why the errors were made in the calculations. The real environmental load from Scenario III (Incinerator) is a corrected 19,309 load units, over five times that of the environmental load of Scenario I (No Incinerator) with a corrected 3,457 load units.

1. The Recycling rate can quickly reach 60% and increase every year thereafter, thereby meeting and exceeding the national targets for diversion of waste from landfills.
2. Scenario I (No Incineration) with a corrected NPV of £235M would cost only half of what Scenario III (Incineration), with a corrected NPV of £463M, would cost.
3. Scenario I (No Incineration), with 3,457 load units has only one fifth of the environmental load of Scenario III (Incineration) with 19,309 load units, if correct environmental factors are used.

Many communities around the Globe have surpassed the 50% recycling goal that has been set by our National Government. The movement towards intensive recycling started in the late 80s.

Seattle, population 1 million, was one of the pioneers. They passed the 50% mark over a ten year period. Initially recycling was costing the city £30 per ton more than landfilling. Now they are saving £50 per ton by recycling rather than disposing.(1) Other communities learned from their experience and have moved faster.

Halifax, Nova Scotia, population 350,000, hired consultants from Seattle to design their recycling system. They had originally planned on incinerating their wastes but when they compared the cost of incineration with intensive recycling they found that the latter was much cheaper. The community planned the strategy in conjunction with the consultants. Their system passed the 50% diversion from disposal point in five years. (2) Nova Scotia, could be a very good model for Connacht as it is mostly a rural community with one large urban center.

Canberra Australia have set a goal of Zero Waste by 2010 and have already exceeded 60% diversion from landfill. 22 councils in New Zealand have adopted a zero waste policy.

The lesson is that using the experience of more mature systems means that progress can be made faster. Ireland learned that lesson well in terms of developing industries like computers/ software. Recycling is just another industry. Also as experience is gained, the cost of recycling has dropped to less than disposal to both landfill and incineration.

1. Community involvement in the planning and operating of the system. Household waste is the most complex, as it contains more mixed materials. Therefore it is the waste stream which requires the most co-operation by participants, both in terms of presenting the material for recycling and in siting the facilities needed for a full waste/resource management system.(3)
2. Systems that are easy for the householder to use. Participation rates in recycling are higher when they are easiest to use. We currently make it easiest to discard by providing a service which picks up waste at the kerbside. On the other hand, people have to bring their recyclables some distance to depots. The kerbside system for Connacht must recognise factors such as space available in differing households to store recyclables and present them for collection. The three wheelie bin system which has been discussed will be extremely difficult for apartments and small terraced houses with no rear access. The Guelph Ontario wet/dry system was developed specifically to overcome this problem in that community.
3. Finding new markets and higher value markets for the materials collected. Seattle initially had difficulty finding markets for glass, but are now getting much higher prices for glass which they sell to the abrasives industry. This material is currently selling at £50 to £70 per ton in the UK.(3) They also found new markets for paper, PET and other plastics, tires etc.
4. Introducing composting of all organics as a first step. This immediately makes a landfill safer as it removes the source of methane and leachate. Composting can be done by both the householder as back yard composting or on a larger scale using either an open aerobic or closed anaerobic system. It must be designed to keep odours within the facility.
5. Introducing and implementing legislation to discourage the production of waste, particularly packaging. The Waste Management Act 1996, include measures which could require manufacturers, distributors and retailers to provide facilities and take back packaging from consumers and design packaging to facilitate recycling. If implemented, it would encourage manufacturers to include disposal costs as part of their product design. Currently that cost is covered by local authorities and taxpayers. Nova Scotia has a return rate of 77% on beverage containers with a mandatory deposit/return system.
6. Setting high reduction/reuse and recycling goals for the industrial and business sector also. Manufacturers have a limited number of materials, which they can control from start to finish, therefore it is easier for them to recover waste materials. This has been recognised by many progressive companies such as Hewlett Packard in Roseville California who are reporting successful diversion from disposal of 97% of their solid waste.(4)
7. Designing a system specifically for the Connacht region that recognises the challenges posed by climate, culture and built environment. Collection of recyclables from households and businesses located on the narrow streets of Galway presents special problems. For instance in the UK they have adapted street sweeper wagons which are used to collect recylables. They run on the pavement thus taking up less space and causing less obstruction than traditional rubbish collection trucks. They also cost less.(5)

Notes:

(1) David Dougherty, Commercial Director, Enviros, Knowledge Innovation Solutions. Speech to the Community Recycling Network Conference in Manchester, April 2000

(2) BioCycle Magazine, April 1999, Page 38. Cart-based Organics Collection, Citizens Drive 65% Diversion System.

(3) David Dougherty, Commercial Director, Enviros, Knowledge Innovation Solutions. Speech to the Community Recycling Network Conference in Manchester, April 2000

(4) Zero Waste, Shining Examples, by Gary Liss, November 1997.

(5) Resource Magazine, April 2000, "Small is Beautiful".

On Page 112 of the Waste Management Strategy Study (from which the Waste Management Plan is derived) the following financial comparison is provided:

It is then stated that "while Scenario III (Incineration) is not the cheapest option the cost difference is quite small."

In the financial analysis in the Waste Management Strategy Study, a figure of £46M is used as the cost of building an incinerator capable of burning 184,000 tonnes/annum. However the most recent incinerator built in Germany (Pirmassens), with a capacity of only 175,000 tonnes/annum cost £141M to build. A more realistic cost, excluding future retrofits, is at least £150M, not £46M.

The cost of operating the incinerator is stated in the Waste Management Strategy Study to be £4.4M, which divided by 184,000 tonnes equates to £24/tonne. However the incinerators visited by representatives of the local authoritites have an annual operating cost of £100-115/ tonne. A more realistic operating cost therefore would be £21M/ annum, not £4M/annum.

The Plan is based on a net cost of £20 per tonne of paper or cardboard recycled, whereas currently there is an actual recovery of £30 per tonne. This reduces the cost of both Scenario I (No Incineration) and Scenario III (Incineration).

The Plan increases the operating costs of Scenario I (No Incineration) from 2007 onwards by £1.3M per annum, for no logical reason whatsoever. These errors have the effect of reducing the cost differential between Scenario I (No Incineration) and Scenario III (Incineration).

The Plan stated that the materials incinerated would produce 5% toxic fly-ash, which for 184,000 tonnes of material incinerated would be 9,400 tonnes/annum. The Irish EPA estimated the cost of disposal of toxic fly-ash to be £100/tonne. The plan does not include for the £1M/annum it would cost to dispose of the toxic fly-ash.

The only environmental factors considered in the plan are the impact on the environment of five selected gases, namely Carbon Dioxide, Sulphur Dioxide, Nitrous Oxides, Carbon Monoxide and Methane.

In the Waste Management Strategy Study data is provided about the emissions of Lead, Cadmium, Mercury, Particles and Dioxins/ Furanes, though the impact of these emissions on the environment and consequently the health of the people of Connacht is not considered:

The United Nations Environmental Program has published the global warming factor to be used for calculation of the impact of methane on global warming. Their number is 21. Yet in the study an incorrect factor of 25 is used, which has the effect of overstating the environmental load from landfill.

Incineration is a major source of Carbon Dioxide. In the calculation of environmental load, the amount of Carbon Dioxide produced per tonne of waste incinerated is 1,240Kg. In the calculation of environmental load, however, the figure actually used is 273 Kg. The actual impact of Incineration on Global Warming, correctly calculated, is five times that in the Plan.

1. The Recycling rate can quickly reach 60% and increase every year thereafter, thereby meeting and exceeding the national targets for diversion of waste from landfills.
2. Scenario I (No Incineration) with a corrected NPV of £235M would cost only half of what Scenario III (Incineration), with a corrected NPV of £463M, would cost.
3. Scenario I (No Incineration), with 3,457 load units has only one fifth of the environmental load of Scenario III (Incineration) with 19,309 load units, if correct environmental factors are used.